G.R. No. 209287, February 3, 2015
Maria Carolina P. Araullo, et al. v. Benigno Simeon C. Aquino III, et al. (Consolidated with G.R. Nos. 209135, 209136, 209155, 209164, 209260, 209442, 209517, 209569)

FACTS

Multiple petitions were filed assailing the constitutionality of acts and practices under the Disbursement Acceleration Program (DAP). The petitioners, including various individuals, party-list representatives, and organizations, challenged the actions of the respondents, primarily the President, the Executive Secretary, and the Secretary of the Department of Budget and Management. The respondents filed a Motion for Reconsideration, and the petitioners in G.R. No. 209442 filed a Motion for Partial Reconsideration of the Court’s Decision promulgated on July 1, 2014. The respondents assailed the decision on procedural grounds (lack of actual case or controversy, lack of jurisdiction, lack of standing) and substantive grounds (proper interpretation of “savings” under the GAA, appropriation cover for DAP applications, Presidential authority to transfer savings, revenue collection requirements, and application of the operative fact doctrine). The petitioners in G.R. No. 209442 partially sought reconsideration on the ground that the Court failed to declare unconstitutional all DAP funds used to augment items without actual deficiencies.

ISSUE

The primary issues involved the Court’s power of judicial review over the constitutional questions raised and the substantive constitutionality of the acts and practices under the DAP, particularly regarding the accumulation and use of “savings” for augmentation.

RULING

The Court denied the motion for partial reconsideration of the petitioners in G.R. No. 209442 and partially granted the motion for reconsideration of the respondents. The procedural challenges raised by the respondents were dismissed as a mere rehash of arguments already passed upon. On substantive challenges, while the grounds were largely reiterations, the Court modified certain declarations from its July 1, 2014 Decision to provide clarification. The Court held that it had the power of judicial review, as the petitions raised questions of constitutionality and allegations of grave abuse of discretion, which are within the Court’s exclusive competence to interpret and apply laws, including the Constitution. The Court emphasized that the power to augment must be strictly construed as it is an exception. The resolution included references to provisions in the 2011, 2012, and 2013 GAAs regarding the use of excess income and reportorial requirements, and cited doctrines such as the operative fact doctrine and good faith.