271059/271347/E-02472/E-04036 Representative Edcel C. Lagman, substituted by Albay First District Representative Krisel B. Lagman, et al. Vs. The Congress of the Philippines, et al./Aquilino “Koko” Pimentel III and Pantaleo “Bebot” Alvarez Vs. Lucas P. Bersamin, in his capacity as executive secretary, and Amenah F. Pangandaman, in her capacity as secretary of the Department of Budget and Management/Filipinos for Peace, Justice and Progress Movement, Inc. (FPJPM), represented by its president and chairperson, Joseph F. Cadsawan, and Gloria T. Puzon, chapter Officer Vs. The House of Representatives, et al./Edgar R. Erice and Leila De Lima Vs. The Senate of the Philippines, et al. — Official PDF

Decision 23 G.R. Nos. 271059, 271347; E-02472 and E-04036 For this reason, the requisites of justiciability, long established in our jurisprndence, must be present in the cases- this-Court resolves: As a rule, "the constitutionality of a statute will be passed on only it~ and to the extent that, it is directly and necessarily involved in a justiciable controversy and is essential to the protection of the rights of the parties concerned." A controversy is said to be justiciable if: first, there is an actual case or controversy involving legal rights that are capable of judicial determination; second, the parties raising the issue must have standing or locus standi to raise the constitutional issue; third, the constitutionality must be raised at the earliest opportunity; and fourth, resolving the constitutionality must be essential to the disposition of the case. 118 First, there is an actual case or controversy when there is a "conflict of legal right, an opposite legal claims susceptible of judicial resolution." 119 It also exists "when there is a clear and convincing showing of a contrariety of legal rights" or when "there are actual facts to enable courts to intelligently adjudicate the issues." 120 In Pimentel Ill v. Matula, 121 there is a contrariety of legal rights as the case involves antagonistic positions of the parties on Special Provision 1( d) of the 2024 GAA and the subject DOF Circular, which mandated the transfer of the Philippine Health Insurance Corporation's fund balance of PHP 89.9 billion to the National Treasury. 122 In Belgica v. Ochoa, 123 there is an actual or justiciable controversy as the requirement of contrariety of legal rights is satisfied by the parties' antagonistic positions on the constitutionality of the pork barrel system. 124 Following Pimentel III v. Matula, there is an actual case or controversy in these cases. The requirement of contrariety of legal rights is satisfied, as evidenced by the antagonistic positions of the parties on the issues raised. 125 The consolidated Petitions question the Legislative branch's exercise of its .. power of the purse in enacting the unprogrammed appropriations for the2024 and 2026 National Budget, as well as the Executive's exercise of its constitutional mandate to implement the same unprogrammed appropriation prov1s10ns. Meanwhile, petitioner Filipinos for Peace is challenging the constitutionality of several provisions concerning the increase of automatic appropriations in the 2025 GAA, particularly the SAGFs and Special Road 118 Corif"ederation for Unity, Recognition and Advancement of Government Employees v. Abad, 889 Phil. 699, 729 (2020) [Per J. Leonen, En Banc]. 11'' KMUv. Aquino Ill, 850 Phil. 1168, 1188 (2019) [Per J. Leonen, En Banc]. 120 Universal Robina Corporation v. Department o_(Trade and !ndusf!J;, 936 Phil. 17, 28 (202_~) [Per S.A.J . . Leonen, En Banc]; Belgica v. Executive Secretary, 864 Phil. 461 (2019) [Per Cwiam, En Banc]. See· also Pimentel III v. Matula, G.R. Nos. 274778, December 3, 2025 [Per J. Lazaro-Javier, En Banc]. 121 G.R. Nos. 274778, 275405 & 276233, December 3, 2025 [Per J. Lazaro-Javier, En Banc]. 122 Id. 12' 721 Phil. 416(2014) [Per J. Perlas-Bernabe, En Banc]. 124 Id. 12s Petition (G.R. No. E-02472), par. 5.3-5.7; Petition (G.R. No. E"04036), p. 18.