Lawyerly

GR Nos. 217126-27

2015-11-10

PERLAS-BERNABE, J.

The foundation of our entire legal system is the Constitution. It is the supreme law of the land;[284] thus, the unbending rule is that every statute should be read in light of the Constitution.[285] Likewise, the Constitution is a framework of a workable government; hence, its interpretation must take into account the complexities, realities, and politics attendant to the operation of the political branches of government.[286]

GR No. 209287

2014-07-01

MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III

BERSAMIN, J.

According to Philippine Constitution Association v. Enriquez:[159] "Impoundment refers to a refusal by the President, for whatever reason, to spend funds made available by Congress. It is the failure to spend or obligate budget authority of any type." Impoundment under the GAA is understood to mean the retention or deduction of appropriations. The 2011 GAA authorized impoundment only in case of unmanageable National Government budget deficit, to wit: Section 66. Prohibition Against Impoundment of Appropriations. No appropriations authorized under this Act shall be impounded through retention or deduction, unless in accordance with the rules and regulations to be issued by the DBM: PROVIDED, That all the funds appropriated for the purposes, programs, projects and activities authorized under this Act, except those covered under the Unprogrammed Fund, shall be released pursuant to Section 33 (3), Chapter 5, Book VI of E.O. No. 292.

GR No. 209287

2014-07-01

MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III

BERSAMIN, J.

(4) Fourth Evidence Packet[14] identifying the DAP-related portions of the Annual Financial Report (AFR) of the Commission on Audit for 2011 and 2012;

GR No. 209287

2014-07-01

MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III

BERSAMIN, J.

This is the background of paragraph 2 of Section 1, which means that the courts cannot hereafter evade the duty to settle matters of this nature, by claiming that such matters constitute a political question. (Bold emphasis supplied)[26]

GR No. 209287

2014-07-01

MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III

BERSAMIN, J.

Public expenditures are also broadly grouped according to their functions into: (1) economic development expenditures (i.e., expenditures on agriculture and natural resources, transportation and communications, commerce and industry, and other economic development efforts);[71] (2) social services or social development expenditures (i.e., government outlay on education, public health and medicare, labor and welfare and others);[72] (3) general government or general public services expenditures (i.e., expenditures for the general government, legislative services, the administration of justice, and for pensions and gratuities); [73] (4) national defense expenditures (i.e., sub-divided into national security expenditures and expenditures for the maintenance of peace and order);[74] and (5) public debt.[75]

GR No. 208566

2013-11-19

GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA

PERLAS-BERNABE, J.

Whether or not (a) the issues raised in the consolidated petitions involve an actual and justiciable controversy; (b) the issues raised in the consolidated petitions are matters of policy not subject to judicial review; (c) petitioners have legal standing to sue; and (d) the Court's Decision dated August 19, 1994 in G.R. Nos. 113105, 113174, 113766, and 113888, entitled "Philippine Constitution Association v. Enriquez"[114] (Philconsa) and Decision dated April 24, 2012 in G.R. No. 164987, entitled "Lawyers Against Monopoly and Poverty v. Secretary of Budget and Management"[115] (LAMP) bar the re- litigation of the issue of constitutionality of the "Pork Barrel System" under the principles of res judicata and stare decisis.

GR No. 208566

2013-11-19

GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA

PERLAS-BERNABE, J.

Under the GAAs for the years 1991 and 1992,[25] CDF funds were, with the approval of the President, to be released directly to the implementing agencies but "subject to the submission of the required list of projects and activities." Although the GAAs from 1990 to 1992 were silent as to the amounts of allocations of the individual legislators, as well as their participation in the identification of projects, it has been reported[26] that by 1992, Representatives were receiving P12.5 Million each in CDF funds, while Senators were receiving P18 Million each, without any limitation or qualification, and that they could identify any kind of project, from hard or infrastructure projects such as roads, bridges, and buildings to "soft projects" such as textbooks, medicines, and scholarships.[27]

GR No. 208566

2013-11-19

GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA

PERLAS-BERNABE, J.

"Pork Barrel" is political parlance of American-English origin.[3] Historically, its usage may be traced to the degrading ritual of rolling out a barrel stuffed with pork to a multitude of black slaves who would cast their famished bodies into the porcine feast to assuage their hunger with morsels coming from the generosity of their well-fed master.[4] This practice was later compared to the actions of American legislators in trying to direct federal budgets in favor of their districts.[5] While the advent of refrigeration has made the actual pork barrel obsolete, it persists in reference to political bills that "bring home the bacon" to a legislator's district and constituents.[6] In a more technical sense, "Pork Barrel" refers to an appropriation of government spending meant for localized projects and secured solely or primarily to bring money to a representative's district.[7] Some scholars on the subject further use it to refer to legislative control of local appropriations.[8]

GR No. 208566

2013-11-19

GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA

PERLAS-BERNABE, J.

The following year, or in 1993,[28] the GAA explicitly stated that the release of CDF funds was to be made upon the submission of the list of projects and activities identified by, among others, individual legislators. For the first time, the 1993 CDF Article included an allocation for the Vice-President.[29] As such, Representatives were allocated P12.5 Million each in CDF funds, Senators, P18 Million each, and the Vice- President, P20 Million.

GR No. 208566

2013-11-19

GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA

PERLAS-BERNABE, J.

Provisions on legislator allocations[75] as well as fund realignment[76] were included in the 2012 and 2013 PDAF Articles; but the allocation for the Vice-President, which was pegged at P200 Million in the 2011 GAA, had been deleted. In addition, the 2013 PDAF Article now allowed LGUs to be identified as implementing agencies if they have the technical capability to implement the projects.[77] Legislators were also allowed to identify programs/projects, except for assistance to indigent patients and scholarships, outside of his legislative district provided that he secures the written concurrence of the legislator of the intended outside-district, endorsed by the Speaker of the House.[78] Finally, any realignment of PDAF funds, modification and revision of project identification, as well as requests for release of funds, were all required to be favorably endorsed by the House Committee on Appropriations and the Senate Committee on Finance, as the case may be.[79]

GR No. 192088

2012-10-09

INITIATIVES FOR DIALOGUE v. POWER SECTOR ASSETS

VILLARAMA, JR., J.

In its Comment With Urgent Motion to Lift Status Quo Ante Order, respondent PSALM prayed for the dismissal of the petition on the following procedural grounds: (a) a petition for certiorari is not the proper remedy because PSALM was not acting as a tribunal or board exercising judicial or quasi-judicial functions when it commenced the privatization of AHEPP; (b) the present petition is rendered moot by the issuance of a Notice of Award in favor of K-Water; (c) assuming the petition is not mooted by such contract award, this Court has no jurisdiction over the subject matter of the controversy involving a political question, and also because if it were the intent of Congress to exclude the AHEPP in the privatization of NPC assets, it should have clearly expressed such intent as it did with the Agus and Pulangui power plants under Sec. 47 of the EPIRA; (d) petitioners' lack of standing to question the bidding process for failure to show any injury as a result thereof, while Rep. Walden Bello likewise does not have such legal standing in his capacity as a duly elected member of the House of Representatives as can be gleaned from the rulings in David v. Arroyo[11] and Philippine Constitutional Association v. Enriquez.[12]

GR No. 192935

2010-12-07

LOUIS 'BAROK' C. BIRAOGO v. PHILIPPINE TRUTH COMMISSION OF 2010

MENDOZA, J.

The Court disagrees with the OSG in questioning the legal standing of the petitioners-legislators to assail Executive Order No. 1. Evidently, their petition primarily invokes usurpation of the power of the Congress as a body to which they belong as members. This certainly justifies their resolve to take the cudgels for Congress as an institution and present the complaints on the usurpation of their power and rights as members of the legislature before the Court. As held in Philippine Constitution Association v. Enriquez,[21]

GR No. 162291

2010-08-11

BANK OF PHILIPPINE ISLANDS v. SHEMBERG BIOTECH CORPORATION

VILLARAMA, JR., J.

In addition, the challenge on the constitutionality of the Interim Rules is a new and belated theory that we should not even entertain. It was not raised before the CA. Well settled is the rule that issues not previously ventilated cannot be raised for the first time on appeal.[27] Relatedly, the constitutional question was not raised at the earliest opportunity. The rule is that when issues of constitutionality are raised, the Court can exercise its power of judicial review only if the following requisites are present: (1) the existence of an actual and appropriate case; (2) a personal and substantial interest of the party raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest possible opportunity; and (4) the constitutional question is the lis mota of the case.[28] In Umali v. Guingona, Jr.,[29] the constitutionality of the creation of the Presidential Commission on Anti-Graft and Corruption was raised in the motion for reconsideration of the RTC's decision. This Court did not entertain the constitutional issue because it was belatedly raised at the RTC.

GR No. 127545

2008-04-23

ANDRES SANCHEZ v. COA

TINGA, J,

In Philippine Constitution Association v. Enriquez,[35] the Court declared that individual members of Congress may only determine the necessity of the realignment of savings in the allotments for their operating expenses because they are in the best position to know whether there are savings available in some items and whether there are deficiencies in other items of their operating expenses that need augmentation. However, it is the Senate President and the Speaker of the House of Representatives who shall approve the realignment.[36]

GR NO. 174153

2006-10-25

RAUL L. LAMBINO v. COMELEC

CARPIO, J.

The Lambino Group did not attach to their present petition with this Court a copy of the paper that the people signed as their initiative petition. The Lambino Group submitted to this Court a copy of a signature sheet[20] after the oral arguments of 26 September 2006 when they filed their Memorandum on 11 October 2006. The signature sheet with this Court during the oral arguments was the signature sheet attached[21] to the opposition in intervention filed on 7 September 2006 by intervenor Atty. Pete Quirino-Quadra.

GR No. 152895

2004-06-15

OFELIA V. ARCETA v. MA. CELESTINA C. MANGROBANG

QUISUMBING, J.

But let us return to basics. When the issue of unconstitutionality of a legislative act is raised, it is the established doctrine that the Court may exercise its power of judicial review only if the following requisites are present: (1) an actual and appropriate case and controversy exists; (2) a personal and substantial interest of the party raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest opportunity; and (4) the constitutional question raised is the very lis mota of the case.[7] Only when these requisites are satisfied may the Court assume jurisdiction over a question of unconstitutionality or invalidity of an act of Congress. With due regard to counsel's spirited advocacy in both cases, we are unable to agree that the abovecited requisites have been adequately met.

GR No. 160261

2003-11-10

ERNESTO B. FRANCISCO v. HOUSE OF REPRESENTATIVES

CARPIO MORALES, J.

The historiography of our impeachment provisions will show that they were liberally lifted from the US Constitution. Following an originalist interpretation, there is much to commend to the thought that they are political in nature and character. The political character of impeachment hardly changed in our 1935, 1973 and 1987 Constitutions. Thus, among the grounds of impeachment are "other high crimes or betrayal of public trust."[43] They hardly have any judicially ascertainable content. The power of impeachment is textually committed to Congress, a political branch of government. The right to accuse is exclusively given to the House of Representatives.[44] The right to try and decide is given solely to the Senate[45] and not to the Supreme Court. The Chief Justice has a limited part in the process - - -to preside but without the right to vote when the President is under impeachment.[46] Likewise, the President cannot exercise his pardoning power in cases of impeachment.[47] All these provisions confirm the inherent nature of impeachment as political.

GR No. 141284

2000-08-15

INTEGRATED BAR OF PHILIPPINES v. RONALDO B. ZAMORA

KAPUNAN, J.

raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest opportunity; and (4) the constitutional question is the lis mota of the case.[12] The IBP has not sufficiently complied with the requisites of standing in this case.

	GR Nos. 217126-27 2015-11-10	CONCHITA CARPIO MORALES v. CA PERLAS-BERNABE, J.
The foundation of our entire legal system is the Constitution. It is the supreme law of the land;[284] thus, the unbending rule is that every statute should be read in light of the Constitution.[285] Likewise, the Constitution is a framework of a workable government; hence, its interpretation must take into account the complexities, realities, and politics attendant to the operation of the political branches of government.[286]
	GR No. 209287 2014-07-01	MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III BERSAMIN, J.
According to Philippine Constitution Association v. Enriquez:[159] "Impoundment refers to a refusal by the President, for whatever reason, to spend funds made available by Congress. It is the failure to spend or obligate budget authority of any type." Impoundment under the GAA is understood to mean the retention or deduction of appropriations. The 2011 GAA authorized impoundment only in case of unmanageable National Government budget deficit, to wit: Section 66. Prohibition Against Impoundment of Appropriations. No appropriations authorized under this Act shall be impounded through retention or deduction, unless in accordance with the rules and regulations to be issued by the DBM: PROVIDED, That all the funds appropriated for the purposes, programs, projects and activities authorized under this Act, except those covered under the Unprogrammed Fund, shall be released pursuant to Section 33 (3), Chapter 5, Book VI of E.O. No. 292.
	GR No. 209287 2014-07-01	MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III BERSAMIN, J.
(4) Fourth Evidence Packet[14] identifying the DAP-related portions of the Annual Financial Report (AFR) of the Commission on Audit for 2011 and 2012;
	GR No. 209287 2014-07-01	MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III BERSAMIN, J.
This is the background of paragraph 2 of Section 1, which means that the courts cannot hereafter evade the duty to settle matters of this nature, by claiming that such matters constitute a political question. (Bold emphasis supplied)[26]
	GR No. 209287 2014-07-01	MARIA CAROLINA P. ARAULLO v. BENIGNO SIMEON C. AQUINO III BERSAMIN, J.
Public expenditures are also broadly grouped according to their functions into: (1) economic development expenditures (i.e., expenditures on agriculture and natural resources, transportation and communications, commerce and industry, and other economic development efforts);[71] (2) social services or social development expenditures (i.e., government outlay on education, public health and medicare, labor and welfare and others);[72] (3) general government or general public services expenditures (i.e., expenditures for the general government, legislative services, the administration of justice, and for pensions and gratuities); [73] (4) national defense expenditures (i.e., sub-divided into national security expenditures and expenditures for the maintenance of peace and order);[74] and (5) public debt.[75]
	GR No. 208566 2013-11-19	GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA PERLAS-BERNABE, J.
Whether or not (a) the issues raised in the consolidated petitions involve an actual and justiciable controversy; (b) the issues raised in the consolidated petitions are matters of policy not subject to judicial review; (c) petitioners have legal standing to sue; and (d) the Court's Decision dated August 19, 1994 in G.R. Nos. 113105, 113174, 113766, and 113888, entitled "Philippine Constitution Association v. Enriquez"[114] (Philconsa) and Decision dated April 24, 2012 in G.R. No. 164987, entitled "Lawyers Against Monopoly and Poverty v. Secretary of Budget and Management"[115] (LAMP) bar the re- litigation of the issue of constitutionality of the "Pork Barrel System" under the principles of res judicata and stare decisis.
	GR No. 208566 2013-11-19	GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA PERLAS-BERNABE, J.
Under the GAAs for the years 1991 and 1992,[25] CDF funds were, with the approval of the President, to be released directly to the implementing agencies but "subject to the submission of the required list of projects and activities." Although the GAAs from 1990 to 1992 were silent as to the amounts of allocations of the individual legislators, as well as their participation in the identification of projects, it has been reported[26] that by 1992, Representatives were receiving P12.5 Million each in CDF funds, while Senators were receiving P18 Million each, without any limitation or qualification, and that they could identify any kind of project, from hard or infrastructure projects such as roads, bridges, and buildings to "soft projects" such as textbooks, medicines, and scholarships.[27]
	GR No. 208566 2013-11-19	GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA PERLAS-BERNABE, J.
"Pork Barrel" is political parlance of American-English origin.[3] Historically, its usage may be traced to the degrading ritual of rolling out a barrel stuffed with pork to a multitude of black slaves who would cast their famished bodies into the porcine feast to assuage their hunger with morsels coming from the generosity of their well-fed master.[4] This practice was later compared to the actions of American legislators in trying to direct federal budgets in favor of their districts.[5] While the advent of refrigeration has made the actual pork barrel obsolete, it persists in reference to political bills that "bring home the bacon" to a legislator's district and constituents.[6] In a more technical sense, "Pork Barrel" refers to an appropriation of government spending meant for localized projects and secured solely or primarily to bring money to a representative's district.[7] Some scholars on the subject further use it to refer to legislative control of local appropriations.[8]
	GR No. 208566 2013-11-19	GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA PERLAS-BERNABE, J.
The following year, or in 1993,[28] the GAA explicitly stated that the release of CDF funds was to be made upon the submission of the list of projects and activities identified by, among others, individual legislators. For the first time, the 1993 CDF Article included an allocation for the Vice-President.[29] As such, Representatives were allocated P12.5 Million each in CDF funds, Senators, P18 Million each, and the Vice- President, P20 Million.
	GR No. 208566 2013-11-19	GRECO ANTONIOUS BEDA B. BELGICA v. EXECUTIVE SECRETARY PAQUITO N. OCHOA PERLAS-BERNABE, J.
Provisions on legislator allocations[75] as well as fund realignment[76] were included in the 2012 and 2013 PDAF Articles; but the allocation for the Vice-President, which was pegged at P200 Million in the 2011 GAA, had been deleted. In addition, the 2013 PDAF Article now allowed LGUs to be identified as implementing agencies if they have the technical capability to implement the projects.[77] Legislators were also allowed to identify programs/projects, except for assistance to indigent patients and scholarships, outside of his legislative district provided that he secures the written concurrence of the legislator of the intended outside-district, endorsed by the Speaker of the House.[78] Finally, any realignment of PDAF funds, modification and revision of project identification, as well as requests for release of funds, were all required to be favorably endorsed by the House Committee on Appropriations and the Senate Committee on Finance, as the case may be.[79]
	GR No. 192088 2012-10-09	INITIATIVES FOR DIALOGUE v. POWER SECTOR ASSETS VILLARAMA, JR., J.
In its Comment With Urgent Motion to Lift Status Quo Ante Order, respondent PSALM prayed for the dismissal of the petition on the following procedural grounds: (a) a petition for certiorari is not the proper remedy because PSALM was not acting as a tribunal or board exercising judicial or quasi-judicial functions when it commenced the privatization of AHEPP; (b) the present petition is rendered moot by the issuance of a Notice of Award in favor of K-Water; (c) assuming the petition is not mooted by such contract award, this Court has no jurisdiction over the subject matter of the controversy involving a political question, and also because if it were the intent of Congress to exclude the AHEPP in the privatization of NPC assets, it should have clearly expressed such intent as it did with the Agus and Pulangui power plants under Sec. 47 of the EPIRA; (d) petitioners' lack of standing to question the bidding process for failure to show any injury as a result thereof, while Rep. Walden Bello likewise does not have such legal standing in his capacity as a duly elected member of the House of Representatives as can be gleaned from the rulings in David v. Arroyo[11] and Philippine Constitutional Association v. Enriquez.[12]
	GR No. 192935 2010-12-07	LOUIS 'BAROK' C. BIRAOGO v. PHILIPPINE TRUTH COMMISSION OF 2010 MENDOZA, J.
The Court disagrees with the OSG in questioning the legal standing of the petitioners-legislators to assail Executive Order No. 1. Evidently, their petition primarily invokes usurpation of the power of the Congress as a body to which they belong as members. This certainly justifies their resolve to take the cudgels for Congress as an institution and present the complaints on the usurpation of their power and rights as members of the legislature before the Court. As held in Philippine Constitution Association v. Enriquez,[21]
	GR No. 162291 2010-08-11	BANK OF PHILIPPINE ISLANDS v. SHEMBERG BIOTECH CORPORATION VILLARAMA, JR., J.
In addition, the challenge on the constitutionality of the Interim Rules is a new and belated theory that we should not even entertain. It was not raised before the CA. Well settled is the rule that issues not previously ventilated cannot be raised for the first time on appeal.[27] Relatedly, the constitutional question was not raised at the earliest opportunity. The rule is that when issues of constitutionality are raised, the Court can exercise its power of judicial review only if the following requisites are present: (1) the existence of an actual and appropriate case; (2) a personal and substantial interest of the party raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest possible opportunity; and (4) the constitutional question is the lis mota of the case.[28] In Umali v. Guingona, Jr.,[29] the constitutionality of the creation of the Presidential Commission on Anti-Graft and Corruption was raised in the motion for reconsideration of the RTC's decision. This Court did not entertain the constitutional issue because it was belatedly raised at the RTC.
	GR No. 127545 2008-04-23	ANDRES SANCHEZ v. COA TINGA, J,
In Philippine Constitution Association v. Enriquez,[35] the Court declared that individual members of Congress may only determine the necessity of the realignment of savings in the allotments for their operating expenses because they are in the best position to know whether there are savings available in some items and whether there are deficiencies in other items of their operating expenses that need augmentation. However, it is the Senate President and the Speaker of the House of Representatives who shall approve the realignment.[36]
	GR NO. 174153 2006-10-25	RAUL L. LAMBINO v. COMELEC CARPIO, J.
The Lambino Group did not attach to their present petition with this Court a copy of the paper that the people signed as their initiative petition. The Lambino Group submitted to this Court a copy of a signature sheet[20] after the oral arguments of 26 September 2006 when they filed their Memorandum on 11 October 2006. The signature sheet with this Court during the oral arguments was the signature sheet attached[21] to the opposition in intervention filed on 7 September 2006 by intervenor Atty. Pete Quirino-Quadra.
	GR No. 152895 2004-06-15	OFELIA V. ARCETA v. MA. CELESTINA C. MANGROBANG QUISUMBING, J.
But let us return to basics. When the issue of unconstitutionality of a legislative act is raised, it is the established doctrine that the Court may exercise its power of judicial review only if the following requisites are present: (1) an actual and appropriate case and controversy exists; (2) a personal and substantial interest of the party raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest opportunity; and (4) the constitutional question raised is the very lis mota of the case.[7] Only when these requisites are satisfied may the Court assume jurisdiction over a question of unconstitutionality or invalidity of an act of Congress. With due regard to counsel's spirited advocacy in both cases, we are unable to agree that the abovecited requisites have been adequately met.
	GR No. 160261 2003-11-10	ERNESTO B. FRANCISCO v. HOUSE OF REPRESENTATIVES CARPIO MORALES, J.
The historiography of our impeachment provisions will show that they were liberally lifted from the US Constitution. Following an originalist interpretation, there is much to commend to the thought that they are political in nature and character. The political character of impeachment hardly changed in our 1935, 1973 and 1987 Constitutions. Thus, among the grounds of impeachment are "other high crimes or betrayal of public trust."[43] They hardly have any judicially ascertainable content. The power of impeachment is textually committed to Congress, a political branch of government. The right to accuse is exclusively given to the House of Representatives.[44] The right to try and decide is given solely to the Senate[45] and not to the Supreme Court. The Chief Justice has a limited part in the process - - -to preside but without the right to vote when the President is under impeachment.[46] Likewise, the President cannot exercise his pardoning power in cases of impeachment.[47] All these provisions confirm the inherent nature of impeachment as political.
	GR No. 141284 2000-08-15	INTEGRATED BAR OF PHILIPPINES v. RONALDO B. ZAMORA KAPUNAN, J.
raising the constitutional question; (3) the exercise of judicial review is pleaded at the earliest opportunity; and (4) the constitutional question is the lis mota of the case.[12] The IBP has not sufficiently complied with the requisites of standing in this case.

PHILIPPINE CONSTITUTION ASSOCIATION v. SALVADOR ENRIQUEZ