GR 210503 Leonen (Digest)
G.R. No. 210503, October 8, 2019
Greco Antonious Beda B. Belgica, Petitioner, vs. The Honorable Executive Secretary, The Honorable Secretary of Budget, and the Philippine Congress, as represented by the Honorable Senate President and the Honorable Speaker of the House of Representatives, Respondents.
FACTS
This case involves a Separate Opinion by Justice Leonen in response to a petition. The core constitutional principle invoked is from Article VI, Section 29(1) of the 1987 Constitution, which states that no money shall be paid from the Treasury except pursuant to an appropriation made by law. The discussion centers on the validity of appropriations, particularly those with no discernible purpose, and the distinction between lump-sum and line-item budgeting.
ISSUE
The primary issue addressed is the constitutional requirement for appropriations to have a discernible purpose and the circumstances under which lump-sum appropriations may be justified, particularly for bodies granted fiscal autonomy.
RULING
Justice Leonen concurs in the dismissal of the petition for lack of merit. He agrees that an appropriation item must have a specified singular amount for a specified singular purpose, and an item lacking a discernible purpose is invalid. However, he emphasizes that lump-sum appropriations bounded by general purposes can be justified when required by constitutional or statutory fiscal autonomy. He argues that bodies with fiscal autonomy, such as the judiciary (whose budget cannot be diminished below the previous year’s appropriation), may legitimately receive lump-sum appropriations. This allows them the necessary leeway and creativity in budget implementation while maintaining public accountability through other means, like a detailed resolution from the Supreme Court En Banc. The opinion cautions against a rigid normative view of the budget process that might marginalize the constitutional concept of fiscal autonomy and notes that the discussion on the fine line between “line” and “lump sum” budgeting should be clarified in a more appropriate case.