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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
271059/271347/E-02472/E-04036 — Promulgated October 7, 2026 · 2026 · Supreme Court 2026 / Decision or signed resolution
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DIGITAL P. 24 / 121
Decision 24 G.R. Nos. 271059, 271347, E-02472 and
E-04036
Fund beyond the amounts recommended by the president. Respondent, on the
other hand, mainly asserts that the acts assailed are a valid exercise of
Congress's power of the purse.
Second, to have legal standing, petitioners must show thatthey have a···· •
personal and substantial interest in the case, such that they stand to suffer
direct injury because of the governmental act being cha!leB.ged. 126
There are instances when this Court has relaxed the rule on standing
when public interests require, such as when the matter being raised is of
"transcendental importance, overarching significance to society, or paramount
public interest," 127 when the litigants are taxpayers claiming illegal
disbursement of public funds, or legislators asserting that the "official action
infringes on their prerogatives as legislators:"128
In any event, the Court may allow suits even if the petitioner fails to
show direct injury as the rule on standing is a matter of procedure which can
be relaxed when public interest so requires, such as when the matter is of
transcendental importance, overarching significance to society, or
paramount public interest.
This is the nontraditional or liberal mode of standing. Under this
mode, nontraditional litigants may be accorded standing to sue by the Court,
provided the following requisites are present:jirst,fi1r taxpayers, a claim ()l
illegal disbursement al public .fund1· or that the tax measure is
unconstitutional; second, for voters, a showing of obvious interest iri the •
validity of the election law in question; third, for concerned citizens, a
showing that the issues raised are a/transcendental importance which must
be settled early; andjinally, jiJr legislators, a claim that the qfficial action
complained ol infringes their prerogatives as legislators. 129 (Emphasis
supplied)
In PHILCONSA v. Enriquez, 130 the petitioners were granted standing as
legislators since the issues involved an alleged intrusion by the Executive into
the domain of the Legislature. If Congress's powers are impaired, each
member's powers are also diminished, since their office grants them the right
to participate in exercising those powers. 131 •
In Belgica v. Ochoa, 132 the petitioners therein have standing as citizen-
taxpayers to question the validity of the pork barrel system. As taxpayers,
'they are bound to suffer from the unconstitutional usage of public funds·. In ••
past cases, "taxpayers have been allowed to sue where there is a claim that ~4
121• KMU v. Aquino lf!, 850 Phil. I I 68, I 203 (2019) [Per J. Leonen, En Banc].
127 Pimentel Ill v. Matula. G.R. Nos. 274778, December 3, 2025 [Per J. Lazaro-Javier, En Banc]; See also
Belgica v. Ochoa, 721 Phil. 4 I 6, 528 (2013) [Per J. Perlas-Bernabe, En Banc]. . .
1'.!8 Pimentel ff! v. A!/atula, G.R. Nos. 274778. December 3, 2025 [Per J. Lazaro-Javier, En Banc].
129 Id.
130 Philippine Constitution Association v. Enriquez, 305 Phil. 546 ( 1994) [Per J. Quiason, En Banc].
131 Id. at 563.
m 721 Phil. 416 (2013) [Per J. Perlas-Bernabe, En Banc].
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