SANLAKAS VS EXECUTIVE SECRETARY (2004)

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AMPATUAN v. PUNO

FACTS: After the Maguindanao Massacre, then Pres. Arroyo issued Proclamation 1946, placing
“the Provinces of Maguindanao and Sultan Kudarat and the City of Cotabato under a state of
emergency.” She directed the AFP and the PNP “to undertake such measures as may be allowed
by the Constitution and by law to prevent and suppress all incidents of lawless violence. 3 days
later, she also issued AO 273 transferring supervision of the ARMM to the DILG. She
subsequently issued AO 273-A, which amended the former AO the term “transfer” used to
“delegate”. The petitioners claimed that the President’s issuances encroached the ARMM’s
autonomy, that it constitutes an invalid exercise of emergency powers, and that the President had
no factual basis for declaring a state of emergency, especially in the Province of Sultan Kudarat
and the City of Cotabato, where no critical violent incidents occurred. They want Proc. 1946 and
AO 273 be declared unconstitutional.

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GUINGONA v. CARAGUE

FACTS: Petitioners question the constitutionality of the automatic appropriation for debt service
in the 1990 budget authorized by P.D. No. 81 as Amended by P.D. No. 1177, and by P.D. No.
1967. Petitioners argue that the decrees of then President Marcos became functus oficio when he
was ousted and so the legislative power was restored to Congress on February 2, 1987 when the
Constitution was ratified by the people; that there is a need for a new legislation by Congress
providing for automatic appropriation, but Congress has not approved any such law; and thus the
said P86.8 Billion automatic appropriation in the 1990 budget is an administrative act that rests
on no law, and thus, it cannot be enforced.

That it is inoperative under Section 3, Article XVIII which provides ––

Sec. 3. All existing laws, decrees, executive orders, proclamations, letters of instructions, and
other executive issuances not inconsistent with this Constitution shall remain operative until
amended, repealed, or revoked."

And that the said decrees are inconsistent with Section 24, Article VI: All appropriation, revenue
or tariff bills, bills authorizing increase of the public debt, bills of local application, and private
bills shall originate exclusively in the House of Representatives, but the Senate may propose or
concur with amendments.

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