271059/271347/E-02472/E-04036  Concurring and Dissenting Opinion: Justice Jhosep Y. Lopez — Official PDF

Concumng and Dissenting Opinion 18 G.R. Nos. 271059, 271347, E-02472 & E-04036 mechanism, the Constitution prescribes certain restrictions and requirements for the valid exercise of Congress's power of the purse. Procedurally, all appropriation, revenue or tariff bills, bills authorizing an increase of the public debt, bills oflocal application, and private bills must originate exclusively in the House of Representatives. However, the Senate may propose or concur with amendments, as provided under Article VI, Section 24 of the Constitution. This rationale is rooted in the principles of democratic representation and fiscal accountability. The House of Representatives, whose members ;J,re elected by legislative districts, is considered closer and more directly accountable, to the people. Accordingly, , it is deemed more appropriate for the House to initiate legislative measures that directly affect public funds, taxation, and local interests.76 The Constitution. also prohibits the inclusion of "riders," or provisions that are unrelated to the subject matter of the appropriation bill. The prohibition is explicitly stated in Article VI, Section 25(2) of the Constitution, which provides: Section 25. 2. No prov1s1on or enactment shall be embraceq in the general appropriations bill unless it relates. specifically to some particular appropriation therein. Any such provi_sion or enactment shall be limited in its operation to the appropriation to which it relates. Additiona!Iy, Article VI, Section 26(1) of the Constitution requires that every biHpassed by Congress shall embrace only one subject, which shall be expressed in the title thereof "The t1nity of th.J subject matter of a bill is mandatory in order to prevent hodge-podge or log rolling legislation[.]"77 This ensures that an appropriation bill is not used as a vehicle for passing unrelated laws, an.cl it remains focused solely on budgetary allocations. Too, Article VI, Section 25(3) of the Constitution, in the interest of fairness and equality, dictates that "[t]h1;: procedure in approving appropriations for the Congress shall strictly follow the procedure in approvmg• appropnat1ons•• fi"hdrt.. or m er epa .men;:;t an d agenc,es.'" Meanwhile.• , Article' VI ' Section 26,2)' . of1J1e Constitution states: 76 ACT Teachers Rr:!.p. Tinfo v. President Duterte~ 934 Phil. 212, 260-261 (2023) [Per J. Dimaampao, En Banc]. 71 Atitiw v. z.-,,,mora, 508 ,Phil. 321,335 (2005.H_P~r J. Tinga, En Ba,zcJ. ----------- .~~~--------······-