**Facts:**
1. **Historical Background:** The Cordillera Administrative Region (CAR) was formed after the 1986 peace talks between the government and Cordillera insurgent groups. President Corazon Aquino created the CAR through Executive Order (E.O.) No. 220 in 1987 while using residual legislative powers.
2. **1987 Constitution:** Article X, Sections 15 and 18 of the 1987 Constitution required the creation of autonomous regions in the Cordilleras and enactment of organic acts for autonomy.
3. **Republic Act No. 6766:** Congress enacted this act to create an organic law for the Cordilleras, but it was rejected in a plebiscite in 1990.
4. **General Appropriations Act of 2000:** President Joseph Estrada signed this into law on February 15, 2000. This act included Special Provisions for the winding up of the CAR with an appropriation of P18,379,000.00, a reduction from previous years.
5. **Extension Orders:** President Estrada issued E.O. Nos. 270 and 328 to extend the winding-up period of the CAR until March 31, 2001.
6. **Petition:** Nestor G. Atitiw and other CAR members sought prohibition, mandamus, and declaratory relief to nullify the Special Provisions of the 2000 GAA and demanded funds to resume CAR’s operations.
**Issues:**
1. **Is the Special Provision in the 2000 GAA a Rider and therefore Unconstitutional?**
2. **Can Congress Unilaterally Amend or Repeal E.O. No. 220?**
3. **Should the Republic be Ordered to Honor its Commitments under E.O. No. 220?**
**Court’s Decision:**
1. **Rider Issue:**
– The Court held that the Special Provisions were not a rider, as they specifically related to the appropriations for the CAR.
– Congress has the power to place qualifications, conditions, limitations, or restrictions on appropriations, as long as they are germane to some particular appropriation.
2. **Congressional Powers:**
– The Court decided that Congress holds the power to amend or repeal laws, including E.O. No. 220.
– CAR as established by E.O. No. 220 was not the autonomous region contemplated by the Constitution, thus Congress’s actions were valid.
3. **Compliance with E.O. No. 220 Commitments:**
– The Court noted that the CAR established by E.O. No. 220 was an administrative region, not an autonomous region.
– The plea for executing the provisions or resuming the CAR operations was within the political, legislative and executive domains beyond judicial review.
**Doctrine:**
– **Germaneness Standard in Appropriation Bills:** Provisions in a general appropriations bill must relate specifically to appropriation items and not be foreign to the general subject of the act. Conditions and restrictions must exhibit a connection with the appropriations.
– **Legislative Powers:** Congress possesses unqualified powers to legislate, amend, or repeal any law, except those reserved by the Constitution.
– **Separation of Powers:** Courts cannot review the wisdom or policy considerations of legislative acts; judiciary intervention is only permissible in cases of unconstitutionality or grave abuse of discretion.
**Class Notes:**
1. **Key Elements:**
– **Germaneness in Appropriations:** Appropriation conditions must relate to the main subject and item.
– **Legislative Independence:** Congress can amend or repeal any law except constitutional mandates.
– **Separation of Powers:** Judicial overreach in legislative affairs is restricted.
2. **Relevant Provisions:**
– **Article VI, Section 25(2), Constitution:** No rider provisions in appropriation bills.
– **Article VI, Section 26(1), Constitution:** Every bill must embrace only one subject.
– **Article X, Section 15 & 18, Constitution:** Creation and regulation of autonomous regions.
**Historical Background:**
The case contextualizes the struggle for regional autonomy in the Cordilleras within the post-EDSA political landscape. E.O. 220 was part of wider peace efforts acknowledging ethnic diversity but was hampered by lack of sufficient regional autonomy frameworks, leading to ongoing tensions within a rigid centralized governmental structure.
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