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Philippine Constitution Association, petitioner vs.

Enriquez, respondent
Facts:
RA 7663 (former House bill No. 10900, the General Appropriations Bill of 1994) entitled An
Act Appropriating Funds for the Operation of the Government of the Philippines from January 1
to December 1, 1994, and for other Purposes was approved by the President and vetoed some of
the provisions. Petitioners assail the special provision allowing a member of Congress to realign
his allocation for operational expenses to any other expense category claiming that it violates
Sec. 25, Art 7 of the Constitution. Issues of constitutionality were raised before the Supreme
Court.
PhilConsA prayed for a writ of prohibition to declare unconstitutional and void a.) Art 16 on the
Countrywide Development Fund and b.) The veto of the President of the Special provision of Art
XLVIII of the GAA of 1994. 16 members of the Senate sought the issuance of writs of certiorari,
prohibition and mandamus against the Exec. Secretary, the Sec of Dept of Budget and
Management and the National Treasurer and questions: 1.) Constitutionality of the conditions
imposed by the President in the items of the GAA of 1994 and 2.) the constitutionality of the
veto of the special provision in the appropriation for debt services.
Senators Tanada and Romulo sought the issuance of the writs of prohibition and mandamus
against the same respondents. Petitioners contest the constitutionality of: 1.) veto on four special
provisions added to items in the GAA of 1994 for the AFP and DPWH; and 2.) the conditions
imposed by the President in the implementation of certain appropriations for the CAFGUs,
DPWH, and Natl Highway Authority.
Issue:
Whether or not the petitioners have locus standi.
Held:
We rule that a member of the Senate, and of the House of Representatives for that matter, has the
legal standing to question the validity of a presidential veto or a condition imposed on an item in
an appropriation bill.
To the extent the powers of Congress are impaired, so is the power of each member thereof, since
his office confers a right to participate in the exercise of the powers of that institution.