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Philconsa v Enriquez Petition: certiorari, prohibition, mandamus Petitioner: Philconsa, 16 members of the Senate, FDC Respondent: Sec. Enriquez of the DBM Ponente: Quiason Date: Aug. 19, 1994 Facts: Case at bar is consolidation of 5 cases relating to claims of authority between the Legislative and Executive on the General Appropriations Act of 1994 GAB of 1994 was passed on December 17, 1993; said bill fixed the budget of the government for the following fiscal year. On December 30, President FVR signed the bill into law (turning it to RA 7663). FVR delivered Veto Address on the same day. Petitioners (claiming to have standing as taxpayers and/or legislators) primarily assail the constitutionality of: 1) conditions imposed by the President in some of the items in the budget, and 2) the veto made by FVR on the appropriation for debt service. Particular items/special provisions were on: 1) debt servicing 2) revolving fund for State Universities and Colleges (SUCs) 3) road maintenance by the DPWH 3) purchase of military equipment & medicines 4) AFP pension fund 5) CAFGU deactivation (specific items tackled in the ratio) Pertinent laws/provisions: Sec. 24 & 25, Art. VI pertaining to appropriation bills Sec. 27 (2), Art. VI Presidential power to veto items in money bills Issues: 1. WON petitioners have standing 2. WON veto of special provision for debt ceiling is constitutional 3. WON vetoes and conditions set by the President on particular items are constitutional Ruling: 1. YES 2. YES 3. (See ratio regarding the validity of the particular vetoed items) Ratio Decidendi: 1. Case at bar concerns appropriation of national budget, taxpayer suit stands. Legislators likewise granted standing because the petition touches on the legislative power on appropriation as stated in the Constitution. 2. Debt Servicing was one of the special provisions in the GAA (Guingona Jr. v Carague explains why Congress was allowed to appropriate so much for this item). The President vetoed said special provision, without vetoing the amount set aside by Congress (around 86B pesos). The Court relied on the ruling in Gonzales v Macaraig Jr. that defined inappropriate provisions, which introduced items that are more appropriate to be tackled in a separate legislation. Moreover, the vetoed provision on debt servicing appeared to be an attempt to repeal PD 1177 (Foreign Borrowing Act) and EO 292. Repeal should be made in another law and not in the GAA. Inclusion of debt servicing policy in the GAA was out of place and was clearly an attempt to log-roll legislation; Court sustained the veto since the provision was inappropriate anyway and the action was part of the executives prerogative/presumption that the President will execute the law faithfully. 3. A) on SUCs: Petitioners argue that the Presidents veto of the provision that gave SUCs revolving funds was a grave abuse of discretion, since other govt. agencies were allowed to retain theirs. Court said that