Warth v. Seldin Brief Fact Summary.

Plaintiffs claimed that a local zoning ordinance excluded persons of low and moderate income from living in a certain community. Defendants responded by claiming that Plaintiffs lacked standing to bring suit. Synopsis of Rule of Law. A plaintiff must generally allege a specific case or controversy between herself and the defendant in order to have standing. Facts. The Plaintiffs were various organizations and individuals residing in Rochester, New York (Rochester). The Plaintiffs brought suit against the town of Penfield, New York (Penfield) and members of Penfields Zoning, Planning, and Town Boards (Defendants). Plaintiffs contended that Penfields zoning ordinance effectively excluded persons of low and moderate income from living in the town, in contravention of constitutional and statutory rights. The lower federal courts held that none of the Plaintiffs had standing. Issue. Have the Plaintiffs established that a case or controversy exists between themselves and the Defendants within the meaning of Article III of the United States Constitution (Constitution), in order to have standing? Held. Yes. Judgment affirmed. In order for a federal court to have jurisdiction, the plaintiff himself must have suffered some threatened or actual injury resulting from the putatively legal action. Additionally, standing will generally not be found when: a generalized grievance is shared in substantially equal measure by all or a large class of citizens a plaintiff attempts to claim relief on the legal rights of third parties. Congress may create standing for individuals through statutes who would otherwise lack standing, so long as the plaintiff alleges a distinct and palpable injury to himself. In the present case, the Plaintiffs claimed the enforcement of zoning ordinances against third parties had the effect of precluding the construction of housing suitable to their needs. For standing, a plaintiff must allege that the challenged practices affect him specifically and that court intervention would personally benefit the plaintiff. In order for an organization to have standing, it must claim that all or any one of its members are suffering immediate or threatened injury as a result of the challenged action. Plaintiffs in this case fail to do so. Dissent. The Plaintiffs have submitted a sufficient pleading to avoid a motion to dismiss for lack of standing. The majoritys opinion is based instead on the merits of the claim. Discussion. The purpose of the standing requirement is to prevent the courts from being forced to adjudicate abstract questions of wide public significance, which could better be determined in other forums. Relevant Facts: Petitioners were comprised of various individuals wanting the rezoning of an area within the confines of the City of Penfield NY. Penfield is and exclusive area catering to the moderately wealthy. Petitioners claim that the zoning law, by its terms and as enforced by the defendant board members, excludes people of low to moderate income levels. Legal Issue(s): Whether the petitioners had standing to sue? Courts Holding: Petitioners lack standing to sue. Law or Rule(s): Article III U.S. Constitution, the asserted injury was the consequence of the defendants actions, or that prospective relief will remove the injury. Case or controversy requirement. Procedure: District Court dismissed, Ct. of Appeals affirmed. Affirmed.

Court Rationale: The petitioners must allege specific, concrete, facts demonstrating that the challenged practices harm him. They have not. The attempted third party intervener failed to show that the enforcement of the ordinance against the third party intervener would violate the third partys rights. The petitioners in this action failed to allege an injury resulting from the respondents actions. Plaintiffs Argument: The respondents have caused an injury by the imposition of the zoning law, an petitioners have been denied access to the courts for redress of grievances. Defendants Argument: Petitioners failed to state a claim upon which the court can grant a remedy. There is no injury suffered from the respondents actions.

Craig v. Boren Brief Fact Summary. Oklahoma State maintained different drinking ages between men and women for the consumption of 3.2% alcohol beer. The Appellant, Craig (Appellant), now alleges that this difference violates the Fourteenth Amendment of the United States Constitution (Constitution). Synopsis of Rule of Law. Gender-based classifications must satisfy intermediate scrutiny requirements to pass constitutional muster. Facts. The State of Oklahoma prohibited the sale of nonintoxicating 3.2% alcohol beer to men under the age of 21 and women under the age of 18. Suit was brought against the State, alleging the law violated the Equal Protection clause of the Fourteenth Amendment of the Constitution. Issue. Does the Oklahoma statute violate the Equal Protection clause of the Fourteenth Amendment of the Constitution? Held. Yes. Appeals Court ruling reversed and remanded. Justice William Brennan (J. Brennan) argues that case precedent dictates that an intermediate level of scrutiny should be applied in analyzing the statute. Specifically, the gender-based classification must serve an important government objective and be substantially related to the achievement of such objective. The District Court unequivocally found that the objective to be served by the statute is increased traffic safety. J. Brennan is not persuaded by the Appellees, Craig and others (Appellees), statistics that the statute closely serves the stated objective. As such, it is not constitutional. Dissent. Justice William Rehnquist (J. Rehnquist) dissents on two levels. He believes that rational basis analysis is the appropriate level of scrutiny for gender-based classification. Furthermore, he believes that the intermediate scrutiny applied by the Supreme Court of the United States (Supreme Court) is so diaphanous and elastic as to encourage judicial prejudice. Discussion. Craig v. Boren establishes intermediate scrutiny as the appropriate level of review for gender-based classification. Intermediate scrutiny is distinguished from strict scrutiny at both the objective and means levels. Important government objectives (intermediate) v. compelling government objectives (strict) and substantially related (intermediate) v. narrowly tailored (strict).

KILOSBAYAN v. GUINGONA

GR No. 113375, May 5, 1994 FACTS: Pursuant to Section 1 of the charter of the PCSO (R.A. No. 1169, as amended by B.P. Blg. 42) which grants it the authority to hold and conduct charity sweepstakes races, lotteries and other similar activities, the PCSO decided to establish an on-line lottery system for the purpose of increasing its revenue base and diversifying its sources of funds. Sometime before March 1993, after learning that the PCSO was interested in operating an on-line lottery system, the Berjaya Group Berhad, a multinational company and one of the ten largest public companies in Malaysia, became interested to offer its services and resources to PCSO. As an initial step, Berjaya Group Berhad (through its individual nominees) organized with some Filipino investors in March 1993 a Philippine corporation known as the Philippine Gaming Management Corporation (PGMC), which was intended to be the medium through which the technical and management services required for the project would be offered and delivered to PCSO. Before August 1993, the PCSO formally issued a Request for Proposal (RFP) for the Lease Contract of an on-line lottery system for the PCSO. On 15 August 1993, PGMC submitted its bid to the PCSO. On 21 October 1993, the Office of the President announced that it had given the respondent PGMC the go-signal to operate the countrys on-line lottery system and that the corresponding implementing contract would be submitted not later than 8 November 1993 for final clearance and approval by the Chief Executive. On 4 November 1993, KILOSBAYAN sent an open letter to President Fidel V. Ramos strongly opposing the setting up of the on-line lottery system on the basis of serious moral and ethical considerations. Considering the denial by the Office of the President of its protest and the statement of Assistant Executive Secretary Renato Corona that only a court injunction can stop Malacaang, and the imminent implementation of the Contract of Lease in February 1994, KILOSBAYAN, with its co-petitioners, filed on 28 January 1994 this petition. Petitioner claims that it is a non-stock domestic corporation composed of civic-spirited citizens, pastors, priests, nuns, and lay leaders. The rest of the petitioners, except Senators Freddie Webb and Wigberto Taada and Representative Joker P. Arroyo, are suing in their capacities as members of the Board of Trustees of KILOSBAYAN and as taxpayers and concerned citizens. Senators Webb and Taada and Representative Arroyo are suing in their capacities as members of Congress and as taxpayers and concerned citizens of the Philippines. The public respondents, meanwhile allege that the petitioners have no standing to maintain the instant suit, citing the Courts resolution in Valmonte vs. Philippine Charity Sweepstakes Office. ISSUES: 1. Whether or not the petitioners have locus standi 2. Whether or the Contract of Lease in the light of Section 1 of R.A. No. 1169, as amended by B.P. Blg. 42, which prohibits the PCSO from holding and conducting lotteries in collaboration, association or joint venture with any person, association, company or entity, whether domestic or foreign. is legal and valid. HELD: We find the instant petition to be of transcendental importance to the public. The ramifications of such issues immeasurably affect the social, economic, and moral well-being of the people even in the remotest barangays of the country and the counter-productive and retrogressive effects of the envisioned on-line lottery system are as staggering as the billions in pesos it is expected to raise. The legal standing then of the petitioners deserves recognition and, in the exercise of its sound discretion, this Court hereby brushes aside the procedural barrier which the respondents tried to take advantage of.

The language of Section 1 of R.A. No. 1169 is indisputably clear. The PCSO cannot share its franchise with another by way of collaboration, association or joint venture. Neither can it assign, transfer, or lease such franchise. Whether the contract in question is one of lease or whether the PGMC is merely an independent contractor should not be decided on the basis of the title or designation of the contract but by the intent of the parties, which may be gathered from the provisions of the contract itself. Animus hominis est anima scripti. The intention of the party is the soul of the instrument. Undoubtedly, from the very inception, the PCSO and the PGMC mutually understood that any arrangement between them would necessarily leave to the PGMC the technical, operations, and management aspects of the on-line lottery system while the PSCO would, primarily, provide the franchise. The so-called Contract of Lease is not, therefore, what it purports to be. Woven therein are provisions which negate its title and betray the true intention of the parties to be in or to have a joint venture for a period of eight years in the operation and maintenance of the on-line lottery system. We thus declare that the challenged Contract of Lease violates the exception provided for in paragraph B, Section 1 of R.A. No. 1169, as amended by B.P. Blg. 42, and is, therefore, invalid for being contrary to law. This conclusion renders unnecessary further discussion on the other issues raised by the petitioners. Kilosbayan vs. Morato (G.R. No. 118910. July 17, 1995) 25APR KILOSBAYAN, INCORPORATED, JOVITO R. SALONGA, CIRILO A. RIGOS, ERME CAMBA, EMILIO C. CAPULONG, JR., JOSE T. APOLO, EPHRAIM TENDERO, FERNANDO SANTIAGO, JOSE ABCEDE, CHRISTINE TAN, RAFAEL G. FERNANDO, RAOUL V. VICTORINO, JOSE CUNANAN, QUINTIN S. DOROMAL, SEN. FREDDIE WEBB, SEN. WIGBERTO TAADA, REP. JOKER P. ARROYO, petitioners, vs. MANUEL L. MORATO, in his capacity as Chairman of the Philippine Charity Sweepstakes Office, and the PHILIPPINE GAMING MANAGEMENT CORPORATION, respondents. Ponente: MENDOZA FACTS: [T]his suit was filed seeking to declare the ELA invalid on the ground that it is substantially the same as the Contract of Lease nullified in the first case [decision in G.R. No. 113375 (Kilosbayan, Incorporated v. Guingona, 232 SCRA 110 (1994)) invalidating the Contract of Lease between the Philippine Charity Sweepstakes Office (PCSO) and the Philippine Gaming Management Corp. (PGMC)]. Petitioners maintain (1) that the Equipment Lease Agreement (ELA) is a different lease contract with none of the vestiges of a joint venture which were found in the Contract of Lease nullified in the prior case; (2) that the ELA did not have to be submitted to a public bidding because it fell within the exception provided in E.O. No. 301, 1 (e); (3) that the power to determine whether the ELA is advantageous to the government is vested in the Board of Directors of the PCSO; (4) that for lack of funds the PCSO cannot purchase its own on-line lottery equipment and has had to enter into a lease contract; (5) that what petitioners are actually seeking in this suit is to further their moral crusade and political agenda, using the Court as their forum. ISSUE: Whether or not the ELA between the Philippine Charity Sweepstakes Office and the Philippine Gaming Management Corp. is invalid. HELD:

NO. Petition for prohibition, review and/or injunction was dismissed. Pertinent to the issue, the SC held: xxx (3) that the ELA is valid as a lease contract under the Civil Code and is not contrary to the charter of the Philippine Charity Sweepstakes Office; (4) that under 1(A) of its charter (R.A. 1169), the Philippine Charity Sweepstakes Office has authority to enter into a contract for the holding of an on-line lottery, whether alone or in association, collaboration or joint venture with another party, so long as it itselfholds or conducts such lottery; and (5) That the Equipment Lease Agreement (ELA) in question did not have to be submitted to public bidding as a condition for its validity. RATIO: E.O. No. 301, 1 applies only to contracts for the purchase of supplies, materials and equipment. It does not refer to contracts of lease of equipment like the ELA. The provisions on lease are found in 6 and 7 but they refer to the lease of privately-owned buildings or spaces for government use or of government-owned buildings or spaces for private use, and these provisions do not require public bidding. It is thus difficult to see how E.O. No. 301 can be applied to the ELA when the only feature of the ELA that may be thought of as close to a contract of purchase and sale is the option to buy given to the PCSO. An option to buy is not of course a contract of purchase and sale. Indeed the question is not whether compared with the former joint venture agreement the present lease contract is *more+ advantageous to the government. The question is whether under the circumstances, the ELA is the most advantageous contract that could be obtained compared with similar lease agreements which the PCSO could have made with other parties. Petitioners have not shown that more favorable terms could have been obtained by the PCSO or that at any rate the ELA, which the PCSO concluded with the PGMC, is disadvantageous to the government. SEPARATE OPINIONS: PADILLA, concurring I join the majority in voting for the dismissal of the petition in this case. As to whether or not the ELA is grossly disadvantageous to the government, it should be stressed that the matter involves, basically, a policy determination by the executive branch which this Court should not ordinarily reverse or substitute with its own judgment, in keeping with the time honored doctrine of separation of powers. VITUG, concurring I most humbly reiterate the separate opinion I have made in Kilosbayan, Inc., et al., vs. Teofisto Guingona, Sr., etc., et al. (G.R. No. 113375, promulgated on 05 May 1994). Back to the core of the petition, however, the matter of the legal standing of petitioners in their suit assailing the subject-contract appears to me, both under substantive law and the rules of procedure, to still be an insuperable issue. I have gone over carefully the pleadings submitted in G.R. No. 118910, and I regret my inability to see anything new that can convince me to depart from the view I have expressed on it in G.R. No. 113375. FELICIANO, dissenting

With very great respect, it is submitted that the above conclusion has been merely assumed rather than demonstrated and that what is in fact before this Court does not adequately support such conclusion. REGALADO, dissenting I am constrained to respectfully dissent from the majority opinion premised on the constitutional and procedural doctrines posed and interpreted in tandem therein. I also regret that I have to impose on the majority with this virtual turno en contra when I could have indicated my disaccord by just joining Mr. Justice Davide in his commendably objective presentation of the minority position. I feel, however, that certain views that have been advanced require a rejoinder lest they lapse into the realm of unanimous precedents. DAVIDE, dissenting I register a dissenting vote. I am disturbed by the sudden reversal of our rulings in Kilosbayan, Inc., et al. vs. Guingona, et al. (hereinafter referred to as the first lotto case) regarding the application or interpretation of the exception clause in paragraph B, Section 1 of the Charter of the PCSO (R.A.. No. 1169), as amended by B.P. Blg. 442, and on the issue of locus standi of the petitioners to question the contract of lease involving the on-line lottery system entered into between the Philippine Charity Sweepstakes Office (PCSO) and the Philippine Gaming Management Corporation (PGMC). Such reversal upsets the salutary doctrines of the law of the case, res judicata, and stare decisis. It puts to jeopardy the faith and confidence of the people, specially the lawyers and litigants, in the certainty and stability of the pronouncements of this Court. It opens the floodgates to endless litigations for re-examination of such pronouncements and weakens this Courts judicial and moral authority to demand from lower courts obedience thereto and to impose sanctions for their opposite conduct.

KILOSBAYAN vs. MANUEL L. MORATO G.R. No. 118910. November 16, 1995.

FACTS: In Jan. 25, 1995, PCSO and PGMC signed an Equipment Lease Agreement (ELA) wherein PGMC leased online lottery equipment and accessories to PCSO. (Rental of 4.3% of the gross amount of ticket or at least P35,000 per terminal annually). 30% of the net receipts is allotted to charity. Term of lease is for 8 years. PCSO is to employ its own personnel and responsible for the facilities. Upon the expiration of lease, PCSO may purchase the equipment for P25 million. Feb. 21, 1995. A petition was filed to declare ELA invalid because it is the same as the Contract of Lease Petitioner's Contention: ELA was same to the Contract of Lease.. It is still violative of PCSO's charter. It is violative of the law regarding public bidding. It violates Sec. 2(2) of Art. 9-D of the 1987 Constitution. Standing can no longer be questioned because it has become the law of the case Respondent's reply: ELA is different from the Contract of Lease. There is no bidding required. The power to determine if ELA is advantageous is vested in the Board of Directors of PCSO. PCSO does not have funds. Petitioners seek to further their moral crusade. Petitioners do not have a legal standing because they were not parties to the contract ISSUES: Whether or not the petitioners have standing? HELD:

NO. STARE DECISIS cannot apply. The previous ruling sustaining the standing of the petitioners is a departure from the volved. LAW OF THE CASE cannot also apply. Since the present case is not the same one litigated by theparties before in Kilosbayan vs. Guingona, Jr., the ruling cannot be in any sense be regarded as the law of this case. The parties are the same but the cases are not. RULE ON CONCLUSIVENESS cannot still apply. An issue actually and directly passed upon and determine in a former suit cannot again be drawn in question in any future action between the same parties involving a different cause of action. But the rule does not apply to issues of law at least when substantially unrelated claims are involved. When the second proceeding involves an instrument or transaction identical with, but in a form separable from the one dealt with in the first proceeding, the Court is free in the second proceeding to make an independent examination of the legal matters at issue. Since ELA is a different contract, the previous decision does not preclude determination of the petitioner's standing. STANDING is a concept in constitutional law and here no constitutional question is actually involved. The more appropriate issue is whether the petitioners are REAL PARTIES in INTEREST. Francisco v. Fernando EN BANC ERNESTO B. FRANCISCO, JR.,G.R. No. 166501 Petitioner, - versus - HON. BAYANI F. FERNANDO, in his capacity as Chairman of the Metropolitan Manila Development Authority, and METROPOLITAN MANILA DEVELOPMENT AUTHORITY, Respondents.November 16, 2006 x - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x R E S O L U T I O N CARPIO,J.: Petitioner Ernesto B. Francisco, Jr. (petitioner), as member of the Integrated Bar of the Philippines and taxpayer, filed this original action for the issuance of the writs of Prohibition and Mandamus. Petitioner prays for the Prohibition writ to enjoin respondents Bayani F. Fernando, Chairman of the Metropolitan Manila Development Authority (MMDA) and the MMDA (respondents) from further implementing its wet flag scheme (Flag Scheme). The Mandamus writ is to compel respondents to respect and uphold the x x x rights of pedestrians to due process x x x and equal protection of the laws x x x. Petitioner contends that the Flag Scheme: (1) has no legal basis because the MMDAs governing body, the Metro Manila Council, did not authorize it; (2) violates the Due Process Clause because it is a summary punishment for jaywalking; (3) disregards the Constitutional protection against cruel, degrading, and inhuman punishment; and (4) violates pedestrian rights as it exposes pedestrians to various potential hazards. In their Comment, respondents sought the dismissal of the petition for petitioners lack of standing to litigate and for violation of the doctrine of hierarchy of courts. Alternatively, respondents contended that the Flag Scheme is a valid preventive measure against jaywalking. Petitioner filed a Reply, claiming that the Court should take cognizance of the case as it raises issues of paramount and transcendental importance. Petitioner also contended that he filed this petition directly with the Court because the issues raised in the petition deserve the directx x x intervention of the x x x *C+ourt x x x. We dismiss the petition.

A citizen can raise a constitutional question only when (1) he can show that he has personally suffered some actual or

threatened injury because of the allegedly illegal conduct of the government; (2) the injury is fairly traceable to the challenged action; and (3) a favorable action will likely redress the injury. On the other hand, a party suing as a taxpayer must specifically show that he has a sufficient interest in preventing the illegal expenditure of money raised by taxation and that he will sustain a direct injury as a result of the enforcement of the questioned statute. Petitioner meets none of the requirements under either category. Nor is there merit to petitioners claim that the Court should relax the standing requirement because of the transcendental importance of the issues the petition raises.As an exception to the standing requirement, the transcendental importance of the issues raised relates to the merits of the petition. Thus, the party invoking it must show, among others, the presence of a clear disregard of a constitutional or statutory prohibition. Petitioner has not shown such clear constitutional or statutory violation. On the Flag Schemes alleged lack of legal basis, we note thatall the cities and municipalities within the MMDAs jurisdiction, except Valenzuela City, have each enacted anti-jaywalking ordinances or traffic managementcodes with provisions for pedestrian regulation. Such fact serves as sufficient basis for respondents implementation of schemes, or ways and means, to enforce the anti-jaywalking ordinances and similar regulations.After all, the MMDA is an administrative agency tasked with the implementation of rules and regulations enacted by proper authorities. The absence of an anti-jaywalking ordinance instyle="font-size: 14pt; line-height: 28px; "Valenzuelastyle="font-size: 14pt; line-height: 28px; "Citydoes not detract from this conclusion absent any proof that respondents implemented the Flag Scheme in that city. Further, the petition ultimately calls for a factual determination of whether the Flag Scheme is a reasonable enforcement of anti-jaywalking ordinances and similar enactments.This Court is not a trier of facts. The petition proffers mere surmises and speculations on the potential hazards of the Flag Scheme.This Court cannot determine the reasonableness of the Flag Scheme based on mere surmises and speculations. Lastly, petitioner violated the doctrine of hierarchy of courts when he filed this petition directly with us. This Courts jurisdiction to issue writs of certiorari, prohibition, mandamus, quo warranto, and habeas corpus, while concurrent with the Regional Trial Courts and the Court of Appeals, does not give litigants unrestrained freedom of choice of forum from which to seek such relief. We relax this rule only in exceptional and compelling circumstances. This is not the case here. WHEREFORE, SO ORDERED. 235 SCRA 506 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. we DISMISS the petition.

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 veto of the president on four special provisions is constitutional and valid? Held: Special Provision on Debt Ceiling Congress provided for a debt-ceiling. Vetoed by the Pres. w/o vetoing the entire appropriation for debt service. The said provisions are germane to & have direct relation w/ debt service. They are appropriate provisions & cannot be vetoed w/o vetoing the entire item/appropriation. VETO VOID. Special Provision on Revolving Funds for SCUs said provision allows for the use of income & creation of revolving fund for SCUs. Provision for Western Visayas State Univ. & Leyte State Colleges vetoed by Pres. Other SCUs enjoying the privilege do so by existing law. Pres. merely acted in pursuance to existing law. VETO VALID. Special Provision on Road Maintenance Congress specified 30% ratio fo works for maintenance of roads be contracted according to guidelines set forth by DPWH. Vetoed by the Pres. w/o vetoing the entire appropriation. It is not an inappropriate provision; it is not alien to the subj. of road maintenance & cannot be veoted w/o vetoing the entire appropriation. VETO VOID. Special Provision on Purchase of Military Equip. AFP modernization, prior approval of Congress required before release of modernization funds. It is the so-called legislative veto. Any prov. blocking an admin. action in implementing a law or requiring legislative approval must be subj. of a separate law. VETO VALID. Special Provision on Use of Savings for AFP Pensions allows Chief of Staff to augment pension funds through the use of savings. According to the Consttution, only the Pres. may exercise such power pursuant to a specific law. Properly vetoed. VETO VALID. Special Provision on Conditions for de-activation of CAFGUs use of special fund for the compensation of the said CAFGUs. Vetoed, Pres. requires his prior approval. It is also an amendment to existing law (PD No. 1597 & RA No. 6758). A provision in an appropriation act cannot be used to repeal/amend existing laws. VETO VALID. 72 Normal 0 false false false EN-US X-NONE X-