GR 166715; (August, 2008) (Digest)
G.R. No. 166715 ; August 14, 2008
ABAKADA GURO PARTY LIST, et al., petitioners, vs. HON. CESAR V. PURISIMA, et al., respondents.
FACTS
Petitioners, invoking taxpayer standing, filed a petition for prohibition to challenge the constitutionality of Republic Act No. 9335 , the Attrition Act of 2005. The law aims to optimize revenue collection in the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC) by establishing a Rewards and Incentives Fund and a Revenue Performance Evaluation Board. The system provides rewards for exceeding collection targets and imposes sanctions, including dismissal, for failing to meet them by at least 7.5%. Petitioners argued the law unconstitutionally transforms BIR and BOC personnel into “mercenaries,” violates equal protection by not including other agencies, unduly delegates legislative power to the President by lacking standards for fixing revenue targets, and breaches separation of powers through the creation of a congressional oversight committee tasked with approving the law’s implementing rules and regulations.
ISSUE
The primary issue is whether RA 9335 is unconstitutional on the grounds of undue delegation of legislative power, violation of equal protection, infringement of the separation of powers doctrine, and for allegedly encouraging corruption.
RULING
The Supreme Court upheld the constitutionality of RA 9335, except for the provision creating a congressional oversight committee with the power to approve implementing rules and regulations. The Court found no undue delegation. The law provides a sufficient standard by delegating the authority to fix revenue targets to the President based on the recommendations of the Development Budget and Coordinating Committee, an existing body whose methodology is outlined by law. The equal protection challenge failed because the classification—limiting the law to the BIR and BOC—is based on substantial distinctions. These agencies are the government’s primary revenue collectors, making the reform directly relevant to their unique functions. The allegation that the reward system breeds corruption is speculative and insufficient to invalidate a law presumed constitutional.
However, the Court declared the provision for the Joint Congressional Oversight Committee unconstitutional. Granting this committee the power to approve the implementing rules and regulations constitutes a legislative veto, allowing Congress to participate in the execution of the law. This violates the principle of separation of powers, as the legislative function ends upon the law’s enactment; the subsequent task of implementing it is executive in nature. The unconstitutional provision is severable, leaving the rest of RA 9335 operative.