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Constitutional Law I 321. Guingona Vs Carague

This case involved a challenge to the constitutionality of automatic appropriations for debt service that exceeded the budget for education. The petitioners argued this violated the constitutional mandate to assign the highest budgetary priority to education. However, the Court held that while education should be a high priority, Congress still has discretion to appropriate funds for other purposes like debt service, which is important for the national interest and economic survival. Therefore, the automatic debt service appropriations were not unconstitutional just because they were higher than education spending. Congress has power and judgment to balance different state policies in setting appropriations.

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684 views2 pages

Constitutional Law I 321. Guingona Vs Carague

This case involved a challenge to the constitutionality of automatic appropriations for debt service that exceeded the budget for education. The petitioners argued this violated the constitutional mandate to assign the highest budgetary priority to education. However, the Court held that while education should be a high priority, Congress still has discretion to appropriate funds for other purposes like debt service, which is important for the national interest and economic survival. Therefore, the automatic debt service appropriations were not unconstitutional just because they were higher than education spending. Congress has power and judgment to balance different state policies in setting appropriations.

Uploaded by

VanityHugh
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Constitutional Law I

321. Guingona vs Carague

EN BANC

G.R. No. 94571             April 22, 1991

TEOFISTO T. GUINGONA, JR. and AQUILINO Q. PIMENTEL, JR., petitioners, 


vs.
HON. GUILLERMO CARAGUE, in his capacity as Secretary, Budget &
Management, HON. ROZALINA S. CAJUCOM in her capacity as National Treasurer
and COMMISSION ON AUDIT, respondents.

GANCAYCO, J.:

FACTS:

The 1990 budget consists of P98.4 Billion in automatic appropriation (with P86.8 Billion
for debt service) and P155.3 Billion appropriated under RA 6831, otherwise known as
the General Approriations Act, or a total of P233.5 Billion, while the appropriations for
the DECS amount to P27,017,813,000.00.

The said automatic appropriation for debt service is authorized by PD No. 18, entitled “
Amending Certain Provisions of Republic Act Numbered Four Thousand Eight Hundred
Sixty, as Amended (Re: Foreign Borrowing Act), “by PD No. 1177, entitled “Revising the
Budget Process in Order to Institutionalize the Budgetary Innovations of the New
Society,” and by PD No.1967, entitled “An Act Strengthening the Guarantee and
Payment Positions of the Republic of the Philippines on its Contingent Liabilities Arising
out of Relent and Guaranteed Loans by Appropriating Funds For The Purpose.”

The petitioners were questioning the constitutionality of the automatic appropriation for
debt service, it being higher than the budget for education, therefore it is against Section
5(5), Article XIV of the Constitution which mandates to “assign the highest budgetary
priority to education.”

ISSUE:

Whether or not the automatic appropriation for debt service is unconstitutional; it being
higher than the budget for education.

HELD:

No. While it is true that under Section 5(5), Article XIV of the Constitution Congress is
mandated to “assign the highest budgetary priority to education,” it does not thereby
follow that the hands of Congress are so hamstrung as to deprive it the power to
respond to the imperatives of the national interest and for the attainment of other state
policies or objectives.
Constitutional Law I
321. Guingona vs Carague

Congress is certainly not without any power, guided only by its good judgment, to
provide an appropriation, that can reasonably service our enormous debt…It is not only
a matter of honor and to protect the credit standing of the country. More especially, the
very survival of our economy is at stake. Thus, if in the process Congress appropriated
an amount for debt service bigger than the share allocated to education, the Court finds
and so holds that said appropriation cannot be thereby assailed as unconstitutional

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