Act Teachers et al vs Pres Duterte

Act Teachers et al vs Pres Duterte et al, GR 236118, Jan 24, 2023
Facts:
 The case involves two consolidated petitions challenging the constitutionality of Republic
Act (RA) No. 10963, known as the Tax Reform for Acceleration and Inclusion (TRAIN)
Act.
 Petitioners in G.R. No. 236118 are ACT Teachers Rep. Antonio Tinio, Bayan Muna Rep.
Carlos Isagani Zarate, and Anakpawis Rep. Ariel "Ka Ayik" Casilao. They filed a
Petition for Certiorari and Prohibition under Rule 65 of the Rules of Court.
 They argue that the TRAIN Act was passed without a quorum in the House of
Representatives on December 13, 2017, violating the 1987 Constitution. They also claim
the law is regressive and burdensome to low-income families.
 Petitioners in G.R. No. 236295, Laban Konsyumer, Inc. and Atty. Victorio Mario A.
Dimagiba, filed a Petition for Certiorari, asserting that the excise taxes imposed by the
TRAIN Act are regressive and discriminatory, violating the due process and equal
protection clauses of the Constitution.
 Respondents, including President Rodrigo Roa Duterte and other high-ranking officials,
argue that the petitions are procedurally infirm and that the TRAIN Act was validly
enacted.
 The Office of the Solicitor General (OSG) contends that the petitions raise political
questions and fail to present an actual case or controversy.
 The Supreme Court, in its decision dated January 24, 2023, addressed these issues.
Issue:
1. Did the Court have jurisdiction to take cognizance of the consolidated petitions?
2. Did the petitioners violate the principle of hierarchy of courts?
3. Is Congress an indispensable party that should have been impleaded in the petitions?
4. Did the inclusion of President Duterte as a respondent violate the doctrine of presidential
immunity from suit?
5. Was the TRAIN Act validly enacted into law?
6. Is the provision amending Section 151 of the Tax Code a prohibited rider?
7. Does the TRAIN Act violate the due process clause?
8. Does the TRAIN Act violate the equal protection clause and Section 28 (1), Article VI of
the Constitution?
Ruling:
1. The Court ruled that it had jurisdiction to take cognizance of the consolidated petitions
under its expanded power of judicial review.
2. The Court found that the petitioners did not violate the principle of hierarchy of courts
due to the presence of genuine issues of constitutionality and the transcendental nature of
the cases.
3. The Court held that the essential and jurisdictional requirement of impleading Congress
as an indispensable party had been substantially complied with.
4. The Court ruled that the inclusion of President Duterte as a party respondent in G.R. No.
236118 contravened the doctrine of presidential immunity from suit.
5. The Court found that the TRAIN Act was validly enacted into law.
6. The Court ruled that Section 48 of the TRAIN Act, which amends Section 151 of the Tax
Code, is not a prohibited rider.
7. The Court held that the assailed provisions of the TRAIN Act do not violate the due
process clause under the Constitution.
8. The Court ruled that the TRAIN Act does not violate the equal protection clause and
Section 28 (1), Article VI of the Constitution.
Ratio:
1. The Court's expanded judicial power under Section 1, Article VIII of the 1987
Constitution allows it to determine whether there has been grave abuse of discretion by
any branch or instrumentality of the Government. The petitions presented an actual case
or controversy, as the TRAIN Act's enactment and its alleged effects on the petitioners
and the public constituted a justiciable issue.
2. The Court recognized exceptions to the doctrine of hierarchy of courts, such as genuine
issues of constitutionality and matters of transcendental importance. The petitions raised
significant constitutional questions that warranted direct resort to the Supreme Court.
3. The Court found that the petitioners in G.R. No. 236295 had impleaded the heads of both
Houses of Congress in their official capacities, which substantially complied with the
requirement of impleading Congress as an indispensable party.
4. The doctrine of presidential immunity from suit, which is rooted in the recognition of the
President's vast and significant functions, precludes the inclusion of the President as a
respondent during his tenure. The Court ordered the dropping of President Duterte as a
party respondent.
5. The Court held that the presence of a quorum at the beginning of the House session on
December 13, 2017, was established, and the Journal entries and the enrolled bill doctrine
supported the validity of the TRAIN Act's enactment. The Court refused to look beyond
these official documents to question the proceedings of a co-equal branch of government.
6. The Court ruled that the Senate's introduction of amendments to the House revenue bill,
including the provision amending Section 151 of the Tax Code, was within its
constitutional power to propose amendments. The provision was germane to the subject
matter and purposes of the House bill.
7. The Court found that the petitioners failed to provide clear and convincing evidence that
the TRAIN Act's provisions on excise taxes were arbitrary, unreasonable, or confiscatory.
The law's social welfare measures and the presumption of constitutionality supported its
validity.
8. The Court held that the petitioners did not demonstrate a clear and unequivocal breach of
the equal protection clause. The TRAIN Act's provisions did not specifically or expressly
discriminate against the poor, and the law's overall impact and social welfare measures
were reasonable and sound legislative judgments.

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Act Teachers et al vs Pres Duterte et al, GR 236118, Jan 24, 2023

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