G.R. No. 207118 , April 22, 2025
Case Parties: [Case name not fully provided in prompt; context indicates a challenge involving Barangay fundraising and PAGCOR’s authority]

FACTS

The core dispute centered on whether barangays, as local government units, could conduct fundraising activities, specifically bingo games, without securing permits from national government agencies, including the Philippine Amusement and Gaming Corporation (PAGCOR). The national government, through PAGCOR and the Department of the Interior and Local Government, asserted regulatory authority over such games, arguing they fell under PAGCOR’s franchise to centralize and regulate games of chance. This position was challenged by barangays invoking their fiscal autonomy.
The barangays relied on the explicit grant of power under Section 391(a)(11) of the Local Government Code, which authorizes the Sangguniang Barangay to “hold fund-raising activities for barangay projects without the need of securing permits from any national or local office or agency.” The provision only requires that such activities comply with national policy standards on morals, health, and safety.

ISSUE

Whether barangays are required to secure a permit or license from PAGCOR or any other national agency to conduct fundraising bingo games.

RULING

The Court, through the ponencia, ruled in favor of barangay fiscal autonomy. Justice Leonen’s Concurring Opinion provides the legal logic. The ruling is anchored on the constitutional principle of local autonomy and the clear, unambiguous text of the Local Government Code. Article X, Section 5 of the Constitution grants local governments the power to create their own revenue sources. This is operationalized by the Local Government Code, which mandates a policy of decentralization and self-reliance.
Critically, Section 391(a)(11) of the Code is a specific and categorical grant of power to barangays to hold fundraising activities without any permit requirement from national or local offices. The law does not distinguish the type of fundraising activity, and its plain meaning must prevail. The requirement to comply with national standards on “morals, health, and safety” is a general condition and does not implicitly subject barangay activities to PAGCOR’s licensing regime. To require a PAGCOR permit would contravene the Code’s explicit “without the need of securing permits” clause and undermine the constitutional and statutory policy of fiscal autonomy. The ruling interprets doubts in favor of devolution, affirming that the power granted to barangays is not diminished by PAGCOR’s general franchise to centralize games of chance.