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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. 59 / 121
Decision 59 G.R. Nos. 271059, 271347, E-02472 and
E~04036
organs. The structure expresses a rule of law ideal, which is that government
must proceed in temporarily ordered phases-legislation, administration,
adjudication, and accountability-rather than through undifferentiated
sovereign wi 11.
. In Belgica v. Ochoa,278 there is a violation of the principle of separation
of powers when there is impermissible interference with and/or assumption of
another department's function:
Broadly speaking, there is a violation of the separation of powers
principle when one branch of government unduly encroaches on the domain
of another. US Supreme Court decisions instruct that the principle of
separation of powers may be violated in two (2) ways: firstly, "one branch
may interfere impermissibly with the other's performance of its
constitutionally assigned function"; and "alternatively, the doctrine may
be violated when one branch assumes a function that more properly is
entrusted to another." In other words, there is a violation of the principle
when there is impennissible (a) interference with and/or (b) assumption
of another department's functions. 279 (Emphasis in the original, citations
omitted)
However, jurisprudence recognizes permissible delegation of
legislative power. Province of Pampanga v. Executive Secretary280 explained
the principle of separation of powers and an exception to it:
The power to enact laws is primarily lodged with the legislature,
which is generally prohibited from delegating its legislative functions and
duties and relieving itself from its mandate under the Constitution.
However, the rule is not absolute. Legislative power may be validly
delegated to the president, which power is not actual lawmaking, but is only
limited "to filling in the details in the execution, enforcement[,] or
administration of a law." To be a valid delegated legislative power, it must
not supplant or modify existing laws, including the Constitution, as the
power to create, change, or abolish laws is exclusive to the legislature and
any usurpation of such power renders the issuance invalid.281 (Citations
omitted)
Pelaez v. Auditor Genera/282 discussed the completeness and sufficient
standard tests to constitute a valid delegation of legislative power:
Although Congress may delegate to another branch of the
government the power to fill in the details in the execution, enforcement[,]
or administration of a law, it is essential, to forestall a violation of the
principle of separation of powers, that said law: (a) be complete in itself-
278 721 Phil.4I6(2013) [Per J. Perlas-Bernabe, En Banc].
27') Id at 535.
280 893 Phil. 277 (2021) [Per J. Leonen, En Banc].
281 Id. at 292-294.
182 122 Phil. 965 (1965) [Per J. Conception, En Banc].
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