April 22, 1991 | 196 SCRA 221
Teofisto T. Guingona, Jr. and Aquilino Pimentel, Jr., petitioners
Hon. Guillermo Carague in his capacity as DBM secretary, respondent
FACTS:
For the fiscal year of 1990, Congress passed RA 6831, otherwise known as the GAA Act of 1990. The said budget contained an automatic appropriation of P98.4 billion, of which P86.8 billion was for debt service. This automatic appropriation was made pursuant to three Marcos-era issuances: PDs 81, 1177, and 1967.
The said Act set the appropriation for education at P29.7 billion -- significantly lower than the appropriation for debt service. This was contrary to Section 5, Art. XIV of the 1987 Constitution, which states that "the State shall assign the highest budgetary priority to education."
ISSUES:
1. Whether or not greater budget allocation for debt servicing as opposed to education violates Section 5, Art. XIV of the 1987 Constitution.
2. Whether or not PDs 81, 1177, and 1967 are still operative despite having been issued during the Marcos era.
3. Whether or not automatic appropriation is violative of Section 29(1), Art. VI of the 1987 Constitution.
1. No, the constitutional provision that the highest appropriation should go to education does not mean that the hands of Congress are so humstrung as to deprive it the power to respond to the imperatives of the national interest and the attainment of other state policies/objectives. One of these policies is to ensure that the President can take advantage of favorable economic conditions, such as situations where interest rates are low.
2. Yes, said PDs are still operative. These were not automatically revoked upon the ouster of Marcos. The Court held that these laws remain operative until they are amended, repealed, or revoked, and so long as they are not inconsistent with the Constitution. In addition, the Court dismissed petitioners' argument that the aforecited PDs fall within the ambit of Section 24, Art. VI pertaining to "all appropriation, revenue or tariff bills," mainly because the PDs in question are considered enacted laws and not bills.
3. No, the Court held there was no undue delegation of legislative power because the assailed PDs are complete -- they set out a policy and are complete in their terms, such that the President doesn't have any choice but to implement them.