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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. 29 / 121
Decision 29 G.R. Nos. 271059, 271347, E-02472 and
E-04036
elections. In justifying the certification of the urgency of the bill, the Court
explained inter alia that:
xx x [W]hile the judicial department and this Court are not
bound by the acceptance of the President's certification by
both the House of Representatives and the Senate, prudent
exercise of our powers and respect due our co-equal
branches of government in matters committed to them
by the Constitution, caution a stay of the judicial hand.
Therefore, the President's exercise of the power to issue such
certification is one that should be accorded with due deference. As such,
the Court must refrain from intruding into such matter through the exercise
of its judicial power in the absence of grave abuse of discretion,
considering that the passage of laws is essentially an affair that falls within
the purview of the political branches of government. 156 (Emphasis in the
original, citations omitted)
Consequently, the Court ruled therein that the president's certification
for the immediate enactment of Republic Act No. 11479 or the Anti-Terrorism
.Act .of 2020 was valid.. The Court explained:. "[T]he constant threat of
terrorism, as one of the biggest menaces to national security, definitely
constitutes as an emergency which the State needs to address immediately.".157
In these consolidated cases, the Court clarifies that the Calleja ruling
does not prohibit the judicial review of the power of presidential certification.
Contrary to respondents' position, the Calleja ruling is clear that the Court
may review the factual basis of the president's issuance of a certification ·of
urgency to the extent of determining whether there has been grave abuse of
discretion amounting to a lack or excess of jurisdiction. This is pursuant to
the Court's expanded power of judicial review under Article VIII, Section 1
of the 1987 Constitution. 158
The president certified as urgent the enactment of House Bill No. 8980
"[i]n order to address the need to maintain continuous government operations
following the end of the current fiscal year [F.Y.], to expedite the funding of
various program, projects, and activities for- [F.Y.], 2024, and to ensure
budgetary preparedness that will enable the government to effectively perform
its Constitutional mandate." 159
"'' Id. at 269-270.
157 Id. at 270.
158 CONST., art. VIII, sec. 1 states:
The judicial power shall be vested in one Supreme Court and in such lower comis as may be established
by law. •
Judicial power includes the duty of the courts of justice to settle actual controversies involving rights
which are legally demandable and enforceable, and lo determine whether or no! there has been a grave
abuse of discretion amounting to lack or excess of jurisdiction on the part of any bran~h or
instrumentality of the Government. (Emphasis supplied) • •
15'J Presidential Communications Office, PBBM asks Congress for quick passage of 2024 General
Appropriations Bill, September 20, 2023, available at https://pco.gov.ph/news_releases/pbbm-asks-
congress-for-quick-passage-of-2024-general-appropriations-bill/ (last accessed on July 27, 2026).
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