Viserys is a statistician by profession.

He loves applying his

expertise in probability by playing poker, blackjack, mahjong,
the super lotto, and other games of chance. He wins a lot
and loses a lot more.
He ran for and won a seat in the Philippine Senate.
Consistent with his first love of spreading the use of statistics
to every province in the country, and after finding the
General Appropriations Act (which was already enacted)
insufficient to further his passion, Senator Viserys authored a
bill entitled An Act Appropriating Emergency Funds for the
Philippine Amusement Gaming Corporation and for Other
Purposes. The significant provisions of the bill are as
follows:
Section 2. Declaration of policy. It shall be the
policy of the State to invigorate the governmentsanctioned gambling industry by making a longterm commitment of building at least one (1)
casino in every province and city in the country.
Section 3. Appropriation.The amount of ONE
HUNDRED
TWENTY
MILLION
PESOS
(Php
120,000,000.00) is hereby appropriated for the
use of PAGCOR to start the urgent need for the
construction of new casinos in the different
provinces of the Philippines.
Section 5. Donations to PAGCOR exempt from
donors tax and other kinds of taxes. All donations
made to the PAGCOR by any person shall be
exempt from donors tax and any from other kind
of taxes as defined in the National Internal
Revenue Code.
The bill was passed by Congress first by the Senate and
later by the House of Representatives. President Theon, a
gambling buddy of Senator Viserys, willingly approved the
bill into law.

Rhaegar, a Filipino citizen and dutiful taxpayer, filed before

the Supreme Court a petition for certiorari and prohibition
against Executive Secretary Tywin and Budget Secretary
Balerion to enjoin the government from spending public
funds for the furtherance of legalized gambling, believing
that doing so is detrimental to public morality. He likewise
wants to have the law (as a whole and especially Sections 3
and 5 cited above) declared as void for being created in
violation of the Constitution.
The Supreme Court, unexpectedly, forwarded the petition to
the Manila RTC Br. 991 for judgment due to the doctrine of
judicial hierarchy. The Office of the Solicitor General (OSG),
arguing for the laws constitutionality, handled the cause of
the government without deputation to the assigned
prosecutor.
After the reception of evidence, the RTC, upon motion of both
the OSG and Rhaegar, ordered the parties to file their trial
memorandum through email on or before March 18, 2015,
11:59PM.
Without the need to stay on the morality of legalized
gambling, prepare a trial memorandum for/against the
constitutionality of the assailed law.