G.R. No. 219683 . January 23, 2018.
HON. JONATHAN A. DELA CRUZ and HON. GUSTAVO S. TAMBUNTING, as MEMBERS OF THE HOUSE OF REPRESENTATIVES and as Taxpayers, Petitioners, vs. HON. PAQUITO N. OCHOA JR., in his capacity as the EXECUTIVE SECRETARY; HON. JOSEPH EMILIO A. ABAYA, in his capacity as the SECRETARY OF THE DEPARTMENT OF TRANSPORTATION AND COMMUNICATIONS; HON. FLORENCIO B. ABAD, in his capacity as the SECRETARY OF THE DEPARTMENT OF BUDGET AND MANAGEMENT; and HON. ROSALIA V. DE LEON, in her capacity as the NATIONAL TREASURER, Respondents.

FACTS

Petitioners, Members of the House of Representatives and taxpayers, filed a special civil action for certiorari and prohibition to assail the implementation of the Motor Vehicle License Plate Standardization Program (MVPSP) by the Land Transportation Office (LTO). They argued the program was being implemented using funds appropriated under the General Appropriations Act (GAA) of 2014, which they claimed was unconstitutional. This case followed the earlier case of Jacomille v. Abaya, where the Supreme Court dismissed a challenge to the MVPSP procurement as moot due to the passage of the 2014 GAA, but noted the initial 2013 appropriation was insufficient and the procurement process was irregular.
The petitioners contended that the 2014 GAA appropriation for the MVPSP violated constitutional and statutory provisions. They specifically argued that the item for the program under the DOTC budget was a lump-sum appropriation, improperly classified under the budget line “Motor Vehicle Registration System,” and that it constituted an unconstitutional transfer of appropriations. They asserted this violated the prohibition against post-enactment legislative identification in Araullo v. Aquino III and the constitutional rule that “No law shall be passed authorizing any transfer of appropriations.”

ISSUE

Whether the appropriation for the Motor Vehicle License Plate Standardization Program (MVPSP) in the 2014 General Appropriations Act is constitutional.

RULING

The Supreme Court DISMISSED the petition and upheld the constitutionality of the MVPSP appropriation. The Court ruled that the appropriation was a valid line-item budget, not an unconstitutional lump-sum fund. The legal logic is grounded in budgetary law and the separation of powers. The Court found that the item “Motor Vehicle Registration System” under the LTO’s budget was a specific appropriation with a singular purpose—to fund the registration system, of which the MVPSP for producing license plates is an integral and indispensable component. This classification was deemed a proper exercise of executive prerogative in formulating the budget and legislative discretion in enacting it.
The Court distinguished this from the unconstitutional Pork Barrel system struck down in Araullo, as the MVPSP fund was allocated to an implementing agency (the LTO) for a specific program of that agency, with no post-enactment authority given to legislators to identify projects. The appropriation was for the agency’s implementation of its mandate, not for individual pet projects of lawmakers. Furthermore, the Court found no violation of the rule against transfer of appropriations, as the funds were used for the purpose for which they were appropriated by law. The Court deferred to the wisdom of the political branches in allocating resources for a program within the executive department’s mandate, finding no grave abuse of discretion in its implementation under the 2014 GAA.