Abbas vs. Senate Electoral Tribunal 166 SCRA 651 (1988) GR L-33767 ABBAS V.

SENATE ELECTORAL TRIBUNAL Facts: On October 9, 1987, the petitioners filed before the respondent Tribunal an electioncontest docketed as SET Case No. 002-87 against 22 candidates of the LABAN coalition whowere proclaimed senators-elect in the May 11, 1987 congressional elections by theCommission on Elections. On November 17, 1987, the petitioners, with the exception of Senator Estrada butincluding Senator Juan Ponce Enrile (who had been designated Member of the Tribunalreplacing Senator Estrada, the latter having affiliated with the Liberal Party and resigned asthe Opposition's representative in the Tribunal) filed with the respondent Tribunal a Motionfor Disqualification or Inhibition of the Senators-Members thereof from the hearing andresolution of SET Case No. 002-87 on the ground that all of them are interested parties tosaid case, as respondents therein. Senator Juan Ponce Enrile in the meantime had voluntarily inhibited himself fromparticipating in the hearings and deliberations of the respondent tribunal in both SET CaseNo. 00287 and SET Case No. 001-87, the latter being another contest filed by Augusto'sSanchez against him and Senator Santanina T. Rasul as alternative respondents, citing hispersonal involvement as a party in the two cases. The petitioners, in essence, argue that considerations of public policy and the normsof fair play and due process imperatively require the mass disqualification sought and thatthe doctrine of necessity which they perceive to be the foundation petition of the questionedResolutions does not rule out a solution both practicable and constitutionallyunobjectionable, namely; the amendment of the respondent Tribunal's Rules of procedureso as to permit the contest being decided by only three Members of the Tribunal. The proposed amendment to the Tribunal's Rules (Section 24) requiring theconcurrence of five (5) members for the adoption of resolutions of whatever nature is aproviso that where more than four (4) members are disqualified, the remaining membersshall constitute a quorum, if not less than three (3) including one (1) Justice, and mayadopt resolutions by majority vote with no abstentions. Obviously tailored to fit the situationcreated by the petition for disqualification, this would, in the context of that situation, leavethe resolution of the contest to the only three Members who would remain, all Justices ofthis Court, whose disqualification is not sought. Issue: Whether the proposed amendment to the Tribunal's Rules (Section 24) is neither unfeasible nor repugnant to the Constitution. Held: No. We opine that in fact the most fundamental objection to such proposal lies in theplain terms and intent of the Constitution itself which, in its Article VI, Section 17, createsthe Senate Electoral Tribunal, ordains its composition and defines its jurisdiction andpowers.It seems quite clear to us that in thus providing for a Tribunal to be staffed by both Justices of the Supreme Court and Members of the Senate, the Constitution intended thatboth those "judicial' and 'legislative' components commonly share the duty and authority ofdeciding all contests relating to the election, returns and qualifications of Senators. Therespondent Tribunal correctly stated one part of this proposition when it held that saidprovision "... is a clear expression of an intent that all (such) contests ... shall be resolvedby a panel or body in which their (the Senators') peers in that Chamber are represented."1The other part, of course, is that the constitutional provision just as clearly mandates the participation in the same process of decision of a representative or representatives of the Supreme Court.

Said intent is even more clearly signalled by the fact that the proportion of Senatorsto Justices in the prescribed membership of the Senate Electoral Tribunal is 2 to 1-anunmistakable indication that the "legislative component" cannot be totally excluded fromparticipation in the resolution of senatorial election contests, without doing violence to thespirit and intent of the Constitution. Where, as here, a situation is created which precludes the substitution of anySenator sitting in the Tribunal by any of his other colleagues in the Senate without invitingthe same objections to the substitute's competence, the proposed mass disqualification, ifsanctioned and ordered, would leave the Tribunal no alternative but to abandon a duty thatno other court or body can perform, but which it cannot lawfully discharge if shorn of theparticipation of its entire membership of Senators. It is aptly noted in the first of the questioned Resolutions that the framers of theConstitution could not have been unaware of the possibility of an election contest that wouldinvolve all 24 Senators-elect, six of whom would inevitably have to sit in judgment thereon.Indeed, such possibility might surface again in the wake of the 1992 elections when oncemore, but for the last time, all 24 seats in the Senate will be at stake. Yet the Constitutionprovides no scheme or mode for settling such unusual situations or for the substitution ofSenators designated to the Tribunal whose disqualification may be sought. Litigants in suchsituations must simply place their trust and hopes of vindication in the fairness and sense ofjustice of the Members of the Tribunal. Justices and Senators, singly and collectively. Every Member of the Tribunal may, as his conscience dictates, refrainfromparticipating in the resolution of a case where he sincerely feels that his personal interestsor biases would stand in the way of an objective and impartial judgment. What we aremerely saying is that in the light of the Constitution, the Senate Electoral Tribunal cannotlegally function as such, absent its entire membership of Senators and that no amendmentof its Rules can confer on the three Justices-Members alone the power of valid adjudicationof a senatorial election contest. Pimentel vs. HRET 393 SCRA 227 (2002) GR 141489 Pimentel, et al. v. House of Representives Electoral Tribunal Facts: On 3 March 1995, the Party-List System Act took effect. On 11 May 1998, in accordance with the Party-List System Act, national elections were held which included, for the first time, the election through popular vote of party-list groups and organizations whose nominees would become members of the House. Proclaimed winners were 14 party-list representatives from 13 organizations, including Melvyn D. Eballe, Leonardo Q. Montemayor, Cresente C. Paez, Loretta Ann P. Rosales and Patricia M. Sarenas from party-list groups Association of Philippine Electric Cooperatives[5] (APEC), AlyansangBayanihanngmgaMagsasaka, ManggagawangBukid at Mangingisda (ABA), NATCO Network Party (COOP-NATCCO), Akbayan! Citizens Action Party (AKBAYAN), and Abanse! Pinay (ABANSE). Due to the votes it garnered, APEC was able to send 2 representatives to the House, while the 12 other party-list groups had one representative each. Also elected were district representatives belonging to various political parties. Subsequently, the House constituted its HRET and CA contingent by electing its representatives to these two constitutional bodies. In practice, the procedure involves the nomination by the political parties of House members who are to occupy seats in the House of Representatives Electoral Tribunal (HRET) and the Commission on Appointments (CA). From available records, it does not appear that after the 11 May 1998 elections the partylist groups in the House nominated any of their representatives to the HRET or the CA. As of the date of filing of the present petitions for prohibition and mandamus with prayer for writ of preliminary injunction, the House contingents to the HRET and the CA were composed solely of district representatives belonging to the different political parties. On 18 January 2000, Senator Aquilino Q. Pimentel, Jr. wrote two letters addressed to then Senate President Blas F. Ople, as Chairman of the CA, and to Associate Justice of the Supreme Court Jose A. R. Melo (now

retired), as Chairman of the HRET. The letters requested Senate President Ople and Justice Melo to cause the restructuring of the CA and the HRET, respectively, to include party-list representatives to conform to Sections 17 and 18, Article VI of the 1987 Constitution. In its meeting of 20 January 2000, the HRET resolved to direct the Secretary of the Tribunal to refer Senator Pimentel s letter to the Secretary-General of the House of Representatives. On the same day, HRET Secretary Daisy B. Panga-Vega, in an Indorsement of even date, referred the letter to House of Representatives Secretary General Roberto P. Nazareno. On 2 February 2000, Eballe, et al. filed with this Court their Petitions for Prohibition, Mandamus and Preliminary Injunction (with Prayer for Temporary Restraining Order) against the HRET, its Chairman and Members, and against the CA, its Chairman and Members. They contend that, under the Constitution and the Party-List System Act, party-list representatives should have 1.2 or at least 1 seat in the HRET, and 2.4 seats in the CA. They charge that the HRET, CA, et al. committed grave abuse of discretion in refusing to act positively on the letter of Senator Pimentel. In its Resolution of 8 February 2000, the Court en banc directed the consolidation of GR 141490 with GR 141489. On 11 February 2000, Eballe et al. filed in both cases a motion to amend their petitions to implead then Speaker Manuel B. Villar, Jr. as an additional respondent, in his capacity as Speaker of the House and as one of the members of the CA. The Court granted both motions and admitted the amended petitions. Senator Pimentel filed the present petitions on the strength of his oath to protect, defend and uphold the Constitution and in his capacity as taxpayer and as a member of the CA. He was joined by 5 party-list representatives from APEC, ABA, ABANSE, AKBAYAN and COOPNATCCO as co-petitioners. Issue: [1] Whether the present composition of the House Electoral Tribunal violates the constitutional requirement of proportional representation because there are no party-list representatives in the HRET. [2]: Whether the refusal of the HRET and the CA to reconstitute themselves to include party-list representatives constitutes grave abuse of discretion. Held: [1] NO. The Constitution expressly grants to the House of Representatives the prerogative, within constitutionally defined limits, to choose from among its district and party-list representatives those who may occupy the seats allotted to the House in the HRET and the CA. Section 18, Article VI of the Constitution explicitly confers on the Senate and on the House the authority to elect among their members those who would fill the 12 seats for Senators and 12 seats for House members in the Commission on Appointments. Under Section 17, Article VI of the Constitution, each chamber of Congress exercises the power to choose, within constitutionally defined limits, who among their members would occupy the allotted 6 seats of each chamber s respective electoral tribunal. These constitutional provisions are reiterated in Rules 3 and 4 (a) of the 1998 Rules of the House of Representatives Electoral Tribunal. The discretion of the House to choose its members to the HRET and the CA is not absolute, being subject to the mandatory constitutional rule on proportional representation.[26] However, under the doctrine of separation of powers, the Court may not interfere with the exercise by the House of this constitutionally mandated duty, absent a clear violation of the Constitution or grave abuse of discretion amounting to lack or excess of jurisdiction.[27] Otherwise, the doctrine of separation of powers calls for each branch of government to be left alone to discharge its duties as it sees fit.[28] Neither can the Court speculate on what action the House may take if party-list representatives are duly nominated for membership in the HRET and the CA. The petitions are bereft of any allegation that respondents prevented the party-list groups in the House from participating in the election of members of the HRET and the CA. Neither does it appear that after the 11 May 1998 elections, the House barred the party-list representatives from seeking membership in the HRET or the CA. Rather, it appears from the available facts that the party-list groups in the House at that time simply refrained from participating in the election process. The party-list representatives did not designate their nominees even up to the time they filed the petitions, with the predictable result that the House did not consider any party-list representative for election to the HRET or the CA. As the primary recourse of the party-list representatives lies with the House of Representatives, the Court cannot resolve the issues presented by petitioners at this time.

[2]: There is no grave abuse in the action or lack of action by the HRET and the CA in response to the letters of Senator Pimentel. Under Sections 17 and 18 of Article VI of the 1987 Constitution and their internal rules, the HRET and the CA are bereft of any power to reconstitute themselves. Bondocvs Pineda, 201 SCRA 792 (1991) GR 97710 Facts: In the elections held on May 11, 1987, Marciano Pineda of the LDP and EmigdioBondoc of the NP were candidates for the position of Representative for the Fourth District of Pampanga. Pineda was proclaimed winner. Bondoc filed a protest in the House of Representatives Electoral Tribunal (HRET), which is composed of 9 members, 3 of whom are Justices of the SC and the remaining 6 are members of the House of Representatives (5 members belong to the LDP and 1 member is from the NP). Thereafter, a decision had been reached in which Bondoc won over Pineda. Congressman Camasura of the LDP voted with the SC Justices and Congressman Cerilles of the NP to proclaim Bondoc the winner of the contest. On the eve of the promulgation of the Bondoc decision, Congressman Camasura received a letter informing him that he was already expelled from the LDP for allegedly helping to organize the Partido Pilipino of Eduardo Cojuangco and for allegedly inviting LDP members in Davao Del Sur to join said political party. On the day of the promulgation of the decision, the Chairman of HRET received a letter informing the Tribunal that on the basis of the letter from the LDP, the House of Representatives decided to withdraw the nomination and rescind the election of Congressman Camasura to the HRET.

Issue: Whether or not the House of Representatives, at the request of the dominant political party therein, may change that party s representation in the HRET to thwart the promulgation of a decision freely reached by the tribunal in an election contest pending therein

Held: The purpose of the constitutional convention creating the Electoral Commission was to provide an independent and impartial tribunal for the determination of contests to legislative office, devoid of partisan consideration. As judges, the members of the tribunal must be non-partisan. They must discharge their functions with complete detachment, impartiality and independence even independence from the political party to which they belong. Hence, disloyalty to party and breach of party discipline are not valid grounds for the expulsion of a member of the tribunal. In expelling Congressman Camasura from the HRET for having cast a conscience vote in favor of Bondoc, based strictly on the result of the examination and appreciation of the ballots and the recount of the votes by the tribunal, the House of Representatives committed a grave abuse of discretion, an injustice and a violation of the Constitution. Its resolution of expulsion against Congressman Camasura is, therefore, null and void. Another reason for the nullity of the expulsion resolution of the House of Representatives is that it violates Congressman Camasura s right to security of tenure. Members of the HRET, as sole judge of congressional election contests, are entitled to security of tenure just as members of the Judiciary enjoy security of tenure under the Constitution. Therefore, membership in the HRET may not be terminated except for a just cause, such as, the expiration of the member s congressional term of office, his death, permanent disability, resignation from the political party he represents in the tribunal, formal affiliation with another political party or removal for other valid cause. A member may not be expelled by the House of Representatives for party disloyalty, short of proof that he has formally affiliated with another

Co vs HRET 199 SCRA 692 (1991) GR 92191 and 92192 Facts: The HRET declared that respondent Jose Ong, Jr. is a natural born Filipino citizen and a resident ofLaoang, Northern Samar for voting purposes. The congressional election for the second district of NorthernSamar was held. Among the candidates who vied for the position of representative in the second legislativedistrict are the petitioners, SixtoBalinquit and Antonio Co and the private respondent, Jose Ong, Jr. RespondentOng was proclaimed the duly elected representative of the second district of Northern Samar. The petitioners filed election protests on the grounds that Jose Ong, Jr. is not a natural born citizen of the Philippines and not a resident of the second district of Northern Samar. Issue: Whether or not Jose Ong, Jr. is a citizen of the Philippines. Held: Yes. In the year 1895, the private respondent s grandfather, OngTe, arrived in the Philippines fromChina and established his residence in the municipality of Laoang, Samar. The father of the private respondent,JoseOngChuan was born in China in 1905 but was brought by OngTe to Samar in the year 1915, he filed withthe court an application for naturalization and was declared a Filipino citizen. In 1984, the private respondent married a Filipina named Desiree Lim. For the elections of 1984 and 1986, Jose Ong, Jr. registered himself as a voter of Laoang, Samar, and voted there during those elections. Under the 1973 Constitution, those born of Filipino fathers and those born of Filipino mothers with analien father were placed on equal footing. They were both considered as natural born citizens. Besides, privaterespondent did more than merely exercise his right of suffrage. He has established his life here in thePhilippines. On the issue of residence, it is not required that a person should have a house in order to establish hisresidence and domicile. It is enough that he should live in the municipality or in a rented house or in that of afriend or relative. To require him to own property in order to be eligible to run for Congress would be tantamountto a property qualification. The Constitution only requires that the candidate meet the age, citizenship, votingand residence requirements.

CosetengvsMitra 187 SCRA 377 (199) GR 86649 Facts: Congressional elections of May 11, 1987 resulted in representatives from diverse political parties Petitioner Anna Dominique Coseteng was the only candidate elected under the banner of KAIBA. A year later, the Laban ngDemokratikong Pilipino or LDP was organized as a political party. As 158 out of 202 members of the House of Representatives formally affiliated with the LDP, the House committees, including the House representation in the Commission on Appointments, had to be reorganized. Petitioner Coseteng then wrote a letter to Speaker Ramon Mitra requesting that as representative of KAIBA, she be appointed as a member of the Commission on Appointments and House Electoral Tribunal. On December 5, 1988, the House of Representatives, revised the House majority membership in the Commission on Appointments to conform with the new political alignments by replacing Rep. Raul A. Daza, LP, with Rep. Luis C. Singson, LDP, however, Congressman Ablan, KBL, was retained as the 12th member representing the House minority.

On February 1, 1989, Coseteng and her party, filed this Petition for Extraordinary Legal Writs praying that the Supreme Court declare as null and void the election of respondent Ablan, Verano-Yap, Romero, Cuenco, Mercado, Bandon, Cabochan, Imperial, Lobregat, Beltran, Locsin, and Singson, as members of the Commission on Appointments, to enjoin them from acting as such and to enjoin also the other respondents from recognizing them as members of the Commission on Appointments on the theory that their election to that Commission violated the constitutional mandate of proportional representation Issue: 1. WON the question raised is political. 2. WON the members of the House in the Commission on Appointments were chosen on the basis of proportional representation from the political parties therein as provided in Section 18, Article VI of the 1987 Constitution. Holding/ Held: 1. No, it is not. The political question issue was settled in Daza vs. Singson, where this Court ruled that the legality, and not the wisdom, of the manner of filling the Commission on Appointments as prescribed by the Constitution is justiciable, and, even if the question were political in nature, it would still come within our powers of review under the expanded jurisdiction conferred upon us by Article VIII, Section 1, of the Constitution, which includes the authority to determine whether grave abuse of discretion amounting to excess or lack of jurisdiction has been committed by any branch or instrumentality of the government. 2. Yes, petition is dismissed for lack of merit. Section 18, Article VI of the 1987 Constitution reads: Sec. 18. There shall be a Commission on Appointments consisting of the President of the Senate, as ex oficio Chairman, twelve Senators, and twelve Members of the House of Representatives elected by each House on the basis of proportional representation from the political parties and parties or organizations registered under the party-list system represented therein. The chairman of the Commission shall not vote, except in case of a tie. The Commission shall act on all appointments submitted to it within thirty session days of the Congress from their submission. The commission shall rule by a majority vote of all the Members. (Art. VI, 1987 Constitution.) The composition of the House membership in the Commission on Appointments was based on proportional representation of the political parties in the House. There are 160 members of the LDP in the House. They represent 79% of the House membership (which may be rounded out to 80%). Eighty percent (80%) of 12 members in the Commission on Appointments would equal 9.6 members, which may be rounded out to ten (10) members from the LDP. The remaining two seats were apportioned to the LP (respondent Lorna Verano-Yap) as the next largest party in the Coalesced Majority and the KBL (respondent RoqueAblan) as the principal opposition party in the House. There is no doubt that this apportionment of the House membership in the Commission on Appointments was done on the basis of proportional representation of the political parties therein. There is no merit in the petitioner s contention that the House members in the Commission on Appointments should have been nominated and elected by their respective political parties. The petition itself shows that they were nominated by their respective floor leaders in the House. They were elected by the House (not by their party) as provided in Section 18, Article VI of the Constitution. The validity of their election to the Commission on Appointments-eleven (11) from the Coalesced Majority and one from the minority-is unassailable. Guingonavs Gonzales 214 SCRA 789 (1993) GR 106971

Facts: The mathematical representation of each of the political parties represented in the Senate for the Commission on Appointments (CA) is as follows: LDP 7.5; LP-PDP-LABAN--.5; NPC 2.5; LAKAS-NUCD 1.5. The LDP majority in the Senate converted a fractional half membership into a whole membership of one Senator by adding one-half or .5 to 7.5 to be able to elect respondent Senator Romulo. In so doing, one other party s fractional membership was correspondingly reduced leaving the latter s representation in the CA to less than their proportional representation in the Senate.

Issue: Whether or not there is a violation of Art. VI, Sec. 18

Held: The respondent s claim to membership in the CA by nomination and election of the LDP majority in the Senate is not in accordance with Sec. 18 of Art. VI of the Constitution and therefore violative of the same because it is not in compliance with the requirement that 12 senators shall be elected on the basis of proportional representation of the political parties represented therein. To disturb the resulting fractional membership of the political parties in the CA by adding together 2 halves to make a whole is a breach of the rule on proportional representation because it will give the LDP an added member in the CA by utilizing the fractional membership of the minority political party, who is deprived of half a representation. The provision of Sec. 18 on proportional representation is mandatory in character and does not leave any discretion to the majority party in the Senate to disobey or disregard the rule on proportional representation. The Constitution does not require that the full complement of 12 senators be elected to the membership in the CA before it can discharge its functions and that it is not mandatory to elect 12 senators to the CA. The overriding directive of Art. VI, Sec. 18 is that there must be a proportional representation of the political parties in the membership of the CA and that the specification of 12 members to constitute its membership is merely an indication of the maximum complement allowable under the Constitution. The act of filling up the membership thereof cannot disregard the mandate of proportional representation of the parties even if it results in fractional membership in unusual situations. Even if the composition of the CA is fixed by the Constitution, it can perform its functions even if not fully constituted, so long as it has the required quorum. Pelaezvs Auditor General 15 SCRA 569 (1965_ GR L-23825 Emmanuel PelaezVs. Auditor-General (1965) This is a special civil action for a writ of prohibition with preliminary injunctioninstituted by Emmanuel Pelaez, as Vice President of the Philippines and as taxpayer,against the Auditor General, to restrain him, as well as his representatives andagents, from passing in audit any expenditure of public funds in implementation of the EOs issued by the President creating 33 municipalities and/or any disbursementby said municipalities. FACTS: In 1964, the President, pursuant to Section 68 of the Revised Administrative Codeissued Executive Orders Nos. 93 to 121, 124 and 126 to 129; creating thirty-three(33) municipalities.Petitioner alleges that said executive orders are null and void on the ground thatsaid Section 68 has been impliedly repealed by Republic Act No. 2370 andconstitutes an undue delegation of legislative power.When RA 2370 (The Barrio Charter) provides that barrios may "not be created ortheir boundaries altered nor their names changed" except by Act of Congress or of the corresponding provincial board "upon petition of a majority of the voters in theareas affected" and the "recommendation of the council of the municipality ormunicipalities.Section 68 of RAC, which said EOs are based, provides that the President maydefine or divide the boundary or boundaries of any province, subprovince,municipality, municipal district XXX as the public welfare may require provided, thatthe authorization of the Congress of the Philippines shall first be obtained.Petitioner argues that the President under the new law cannot create a barrio, howmuch more of a municipality which is composed of several barrios.Respondent answered that a new municipality can be created without creating newbarrios, such as, by placing old barrios under the jurisdiction of the newmunicipality. This answer however overlooks on the main import of the petitionersargument, which questions the President s authority to create municipalities.Respondent alleges that the power of the President to create municipalities underthis section does not amount to an undue delegation of legislative power, relyingupon Municipality of Cardona vs. Municipality of Binagonan. ISSUE: WON the President has the legislative authority to issue the EOs creatingmunicipalities. DECISION:

The Court declared the EOs null and void. The Auditor General permanentlyrestrained from passing in audit any expenditure of public funds in implementationof said EOs or any disbursement by the created municipalities. RATIO: The Court said that the respondent s argument based on Cardona vs. Binangonanis untenable because the case do not involve a creation of municipality but atransfer of municipality. The authority to create municipal corporations is essentiallylegislativein nature. It sstrictly a legislative function. The power to fix such common boundary, in order toavoid or settle conflicts of jurisdiction between adjoining municipalities, may partake of anadministrativenature in the adoption of means and ways tocarry into effect the law creating said municipalities.Although Congress may delegate to another branch of the Government the powerto fill in the details in the execution, enforcement or administration of a law, it isessential, to forestall a violation of the principle of separation of powers, that saidlaw:(a) be complete in itself it must set forth therein the policy to be executed,carried out or implemented by the delegate. (b) fix a standard the limits of which are sufficiently determinate or determinable to which the delegate must conform in the performance of his functions.Without the aforementioned standard, there would be no means to determine, withreasonable certainty, whether the delegate has acted within or beyond the scope of his authority. Hence, he could thereby arrogate upon himself the power, not only tomake the law, but worse, to adopt measures inconsistent with the end sought to beattained by the Act of Congress, thus nullifying the principle of separation of powersand the system of checks and balances, and, consequently, undermining the veryfoundation of our Republican system. The Court said that Section 68 of the RAC does not meet these well settledrequirements for a valid delegation of the power to fix the details in theenforcement of a law. It does not enunciate any policy to be carried out orimplemented by the President. It can be noted thatthe executive orders in question were issued after thelegislative bills for the creation of the municipalities involved in this case had failed to pass Congress. A better proof of the fact that the issuance of saidexecutive orders entails the exercise of purely legislative functions can hardly be given. Senate of the PhilsvsErmita GR 169777 April 20 2006 Bengzonvs Senate Blue Riboon Committee 203 SCRA 767 GR 89914 MANDATORY NORECO vs Sang. Panlunsod of Dumaguete 155 SCRA 421 (1987) Gr L-72492 Katrina Petil ABAKADA GURO vsPurisima, GR 166715 Aug 14 2008 MANDATORY Tiovs VRB 151 SCRA 208 (1987) GR L-75697 Kolleen De Guzman Phil. Consti. Assn. vsGimenez 15 SCRA 479 (1965) GR L-23326 Eva Concepcion Lidasanvs COMELEC 21 SCRA 496 (1967) GR 28089 Cathy Costales Lacsonvs Exec Secretary 301 SCRA 298 GR 128096 MANDATORY Cruz vsParas 123 SCRA 569 (1983) GR L-42571 and 42572 Ever Morales Tolentinovs Sec of Finance 235 SCRA 632 (1994) GR 115455 MANDATORY BengzonvsDrilon 208 SCRA 133 (1992) GR 103524

MANDATORY PHILCONSA vs Enriquez 235 SCRA 506 (1994) GR 113105 MANDATORY