Philippine Constitution Association v. Mathay
REITERATIONFacts
The Antecedents: The Philippine Constitution Association, Inc. (PHILCONSA), a non-stock, non-profit association of Filipino citizens and taxpayers, filed a suit against the Acting Auditor General and the Auditor of Congress. They sought to permanently enjoin the officials from authorizing or passing in audit the payment of increased salaries to the Speaker and members of the House of Representatives, as authorized by Republic Act No. 4134 (approved June 10, 1964), before December 30, 1969. Procedural History: The Auditor General requested the Solicitor General to secure a judicial construction of the law. The Solicitor General suggested seeking an opinion from the Secretary of Justice. The Acting Auditor General then directed his representative in Congress to pass in audit and approve the payment of increased salaries within the limits of the Appropriation Act, prompting the filing of the present action. The Petition: Petitioners contend that the implementation of the salary increases by Republic Act No. 4642 (1965-1966 Appropriation Act) violates Article VI, Section 14 of the Constitution, which states that no increase in compensation shall take effect until after the expiration of the full term of all members of the Senate and the House of Representatives approving such increase. They argue that the terms of the Senators who approved Republic Act No. 4134 expire on December 30, 1969, while the terms of the House members expired on December 30, 1965.
Issue(s)
Whether petitioners, as taxpayers, have the legal personality to file the action. Whether the members of the House of Representatives should be joined as parties defendant. Whether Article VI, Section 14 of the Constitution requires the expiration of the full terms of all members of both the Senate and the House of Representatives who approved the salary increase before such increase can take effect.
Ruling
The writ of prohibition is granted. The items of the Appropriation Act for the fiscal year 1965-1966 (Republic Act No. 4642) authorizing the disbursement of increased compensation to members of the Senate and the House of Representatives prior to December 30, 1969, are declared void. Respondents are prohibited from approving and passing in audit any disbursements of the increased compensation authorized by Republic Act No. 4134 before December 30, 1969.
Ratio Decidendi
On the legal personality of petitioners: Petitioners, as taxpayers, have the legal personality to bring an action to restrain officials from wasting public funds through the enforcement of an invalid or unconstitutional law. This is a recognized doctrine in Philippine jurisprudence, supported by several Supreme Court decisions. On the non-joinder of parties: The alleged non-joinder of the members of the House of Representatives as parties defendant is without merit. Since the acts sought to be enjoined were the respondents' (auditors') passing in audit and approval of payment, and not the collection or receipt thereof, only the respondent auditors were indispensable or proper parties defendant. On the effectivity of the salary increase: The Court ruled that Article VI, Section 14 of the Constitution requires the expiration of the full term of all members of both the Senate and the House of Representatives who approved the salary increase before such increase can take effect. The provision refers to "all the members of the Senate and of the House of Representatives" as a single unit. The use of the singular "term" emphasizes that both chambers are considered as one indivisible component of the Legislature for the purpose of this constitutional restriction. The historical context of the provision, tracing its evolution from unicameral to bicameral legislature, shows a consistent intent to deter self-interest by imposing a waiting period until all legislators who approved the increase have completed their terms. Therefore, the increased compensation provided by Republic Act No. 4134 is not operative until December 30, 1969, when the full term of all members of the Senate and House that approved it on June 20, 1964, will have expired. Consequently, the Appropriation Act authorizing disbursement of increased compensation prior to this date is void.
Main Doctrine
The increased compensation provided by Republic Act No. 4134 for Senators and Members of the House of Representatives is not operative until December 30, 1969, when the full term of all members of the Senate and House that approved it on June 20, 1964, will have expired. Consequently, appropriation for such increased compensation may not be disbursed until December 30, 1969. The Appropriation Act for the fiscal year 1965-1966 (Republic Act No. 4642) authorizing disbursement of increased compensation prior to this date is void.