Goh v. Bayron  In this petition, Alroben J.
Goh assails the aforementioned
November 25, 2014| Carpio, J| Recall
Digester: Mercado, Carlo Robert M.
SUMMARY: COMELEC issued Resolutions 9864 and 9882, the first
raising an issue as to the funding of recall elections in Puerto Princesa
City for the position of City Mayor (a post currently held by Mayor
Bayron.), and the second suspending recall elections on the ground
that the COMELEC does not have appropriations to conduct said
election. In essence, COMELEC is arguing that since there is no
specific line-item appropriation, the COMELEC cannot have funds to
conduct the recall election. Petitioner Goh assailed these provisions
before the SC.
The SC, in ruling for Goh, said that the 2014 GAA provides the line
item appropriation to allow the COMELEC to perform its constitutional
mandate of conducting recall elections This is found in the Programs
category of its 2014 budget.Moreover, in the discharge of its functions,
among which is to conduct recall elections, the item named “Current
Operating Expenditures” may be used. More importantly, the
COMELEC admits in its Resolution No. 9882 that the COMELEC has
“a line item for the” Conduct and supervision of elections, referenda,
recall votes and plebiscites” Thus, there is no need for supplemental
legislation to authorize the COMELEC to conduct recall elections for
2014. Moreover, should the funds appropriated in the 2014 GAA be
deemed insufficient, then the COMELEC Chairman may exercise his
authority to augment such line item appropriation from the COMELEC’s
existing savings, as this augmentation is expressly authorized in the
2014 GAA.
DOCTRINE:
Specific appropriation
To be valid, an appropriation must indicate a specific amount and a
specific purpose.
However, the purpose may be specific even if it is broken down into
different related sub-categories of the same nature.
For example, the purpose can be to “conduct elections,” which even if
not expressly spelled out covers regular, special, or recall elections.
The purpose of the appropriation is still specific - to fund elections,
which naturally and logically include, even if not expressly stated, not
only regular but also special or recall elections.
The Constitution only requires a corresponding appropriation for a
specific purpose or program, not for the sub-set of projects or activities
Authority to augment through savings
This (an actual deficiency in its operating funds for the current year) is
a situation that allows for the exercise of the COMELEC Chairman’ss
power to augment actual deficiencies in the item for the “Conduct and
supervision of recall votes” in its budget appropriation.
FACTS
 This case is about the COMELEC Resolutions No. 9864 and 9882
o 9864 found the petition seeking the recall (recall
petition) of Mayor Lucilo R. Bayron (Mayor Bayron)1,
the incumbent mayor of Puerto Princesa City, sufficient
in form and substance. However, Resolution No. 9864
suspended all proceedings under the recall petition
because the Financial Services Department raised an
issue as to the funding of the entire process of recall
o 9882 suspended any proceeding relative to recall as
the recall process, as stated in said Resolution, does
not have an appropriation in the General
Appropriations Act of 2014 and the 2014 GAA does not
provide the COMELEC with legal authority to
commit public funds for the recall process
 In other words, COMELEC is of the position that they do not have
funds to conduct the recall election
1 of elections, referenda, recall votes and
The grounds of the petition for recall was loss of trust and
confidence
brought about by gross violation of pertinent provisions of
the Anti-Graft and Corrupt Practices Act, gross violation of
pertinent provisions of the Code of Conduct and Ethical
Standards for Public Officials, Incompetence, and other
related gross inexcusable negligence/dereliction of duty,
intellectual dishonesty and emotional immaturity
resolutions on the ff points:
o The 2014 GAA provides for an appropriation or line
item budget to serve as a contingency fund for the
conduct of recall elections.
o COMELEC may lawfully augment any supposed
insufficiency in funding for the conduct of recall
elections by utilizing its savings.
o The proper, orderly and lawful exercise of the process
of recall is within the exclusive power and authority of
the respondent commission.
HELD The 2014 GAA provides the line item appropriation to allow the
COMELEC to perform its constitutional mandate of conducting recall
elections. There is no need for supplemental legislation to authorize
the COMELEC to conduct recall elections for 2014.
W/N COMELEC has the authority to a
Intro which is also the summary
 The 1987 Constitution expressly provides the COMELEC with
the power to “[e]nforce and administer all laws and regulations
relative to the conduct of an election, plebiscite, initiative,
referendum, and recall.”
 The 1987 Constitution not only guaranteed the COMELEC’s fiscal
autonomy, but also granted its head, as authorized by law, to
augment items in its appropriations from its savings
o The 2014 GAA provides such authorization to the
COMELEC Chairman
The COMELEC’s budget in the 2014 GAA
Goh
 Goh asserts that the 2014 GAA provided COMELEC with an
appropriation for the conduct of recall elections in the total amount
of Php2,735,321,000.
 As evidence, Goh
o Reproduced the COMELEC’s budget allocation in the
2014 GAA
o Pointed out that the COMELEC has Php1,483,087,000
appropriated under Operations, and that the
Php1,401,501,000 for current operating expenditure
is allocated per region
o Further states that COMELEC’s personnel
themselves admitted to the existence of funds in the ff
situations:
o Atty. Maria Lea R. Alarkon, Acting Director III of the
COMELEC’s FSD, during the 3 September 2013
budget hearing before the Senate’s Subcommittee A of
the Committee on Finance,
 for the specifics of our MFO [Major Final
Output] budget, x x x conduct and
supervision of elections, referenda, recall and
plebiscites, 1,527,815,000;
o Online news article which quoted COMELEC
spokesperson James Jimenez
 saying that “lack of budget (should) not (be)
an issue. x x x We always have a ‘standby’
budget for recall, plebiscite, etc.”
o Letter dated 28 May 2014 from Rep. Isidro T. Ungab,
Chairman of the House of Representative’ Committee
on Appropriations, addressed to Hon. Douglas S.
Hagedorn, Representative of the Third District of
Palawan
 “[t]he FY 2014 budget of the COMELEC as
authorized in the FY 2014 General
Appropriations Act amounts to
P2,735,321,000, of which P1,401,501,000 is
appropriated for the conduct and supervision
plebiscites
COMELEC
 There is a lack of appropriation or line item for a contingency fund
for the conduct of recall elections in the 2014 GAA
 The amount of Php1,483,087,000 referred to by [Goh] allegedly
for the conduct and supervision of election, referenda, recall votes
and plebiscites, actually refers to operating expenditures for
“Personnel Services” under the program “Regulation of Elections.”
 The amount of Php1,401,501,000, on the other hand, is the total deficiencies in the item for the “Conduct and supervision of
amount allotted for “Personnel Services” (Php1,360,975,000) and recall votes” in its budget appropriation.
“Maintenance and Other Operating Expenses”(Php40,526,000)
for Regional Allocation. Debunking COMELEC’s arguments
 I think what COMELEC means here is that the appropriations  The conduct of recall elections requires only operating expenses,
were not specifically for recall elections not capital outlays.
SC o The COMELEC’s existing personnel in Puerto Princesa
I. On issue of absence of specific appropriation are the same personnel who will evaluate the
Rule on appropriations sufficiency of the recall petitions and conduct the recall
 To be valid, an appropriation must indicate a specific amount and elections.
a specific purpose.  There is no constitutional requirement that the budgetary
o However, the purpose may be specific even if it is appropriation must be loaded in “contingent funds”
broken down into different related sub-categories of the o The Congress has plenary power to lodge such
same nature. appropriation in current operating expenditures
 For example, the purpose can be to “conduct
elections,” which even if not expressly spelled Summary-Conclusion
out covers regular, special, or recall elections.  Considering that there is an existing line item appropriation for the
 The purpose of the appropriation is conduct of recall elections in the 2014 GAA, we see no reason
still specific - to fund elections, why the COMELEC is unable to perform its constitutional
which naturally and logically mandate to “enforce and administer all laws and regulations
include, even if not expressly relative to the conduct of recall.”
stated, not only regular but also  Should the funds appropriated in the 2014 GAA be deemed
special or recall elections. insufficient, then the COMELEC Chairman may exercise his
 The Constitution only requires a authority to augment such line item appropriation from the
corresponding appropriation for a COMELEC’s existing savings, as this augmentation is expressly
specific purpose or program, not for authorized in the 2014 GAA.
the sub-set of projects or activities
As applied
 Despite Resolution No. 9882’s statement about the alleged
failure of the 2014 GAA to provide for a line item
appropriation for the conduct of recall elections, we hold that
the 2014 GAA actually expressly provides for a line item
appropriation for the conduct and supervision of recall
elections.
o This is found in the Programs category of its 2014
budget, which the COMELEC admits in its
Resolution No. 9882 is a line item for the “Conduct
and supervision of elections, referenda, recall votes
and plebiscites.”
 In addition, one of the specific constitutional functions of the
COMELEC is to conduct recall elections. When the
COMELEC receives a budgetary appropriation for its
“Current Operating Expenditures” such appropriation
includes expenditures to carry out its constitutional
functions, including the conduct of recall elections.
o Thus, in Socrates v. COMELEC, recall elections were
conducted even without a specific appropriation for
recall elections in the 2002 GAA.
 More importantly, the COMELEC admits in its Resolution No.
9882 that the COMELEC has a line item for the “Conduct and
supervision of elections, referenda, recall votes and plebiscites”

II. On issue of authority of COMELEC Chairperson to augment the

project of “recall elections” from their savings
COMELEC
 Despite the Php2 billion to Php10.7 billion savings existing in the
COMELEC’s coffers, the COMELEC asserts that it cannot legally
fund the exercise of recall elections.
 COMELEC is authorized to augment only for deficiency in
operating expenses, but in recall elections capital outlay is
needed, thus the situation cannot permit the COMELEC to
augment the approproation
SC
 The power to augment from savings lies dormant until authorized
by law. Flexibility in the use of public funds operates only upon
legislative fiat.
As applied
 The 2014 GAA provides a line item appropriation for the
COMELEC’s conduct of recall elections. Since the COMELEC
now admits that it does not have sufficient funds from its current
line item appropriation for the “Conduct and supervision of recall
votes” to conduct an actual recall election (see last roman
numeral), then there is therefore an actual deficiency in its
operating funds for the current year.
 This (an actual deficiency in its operating funds for the
current year) is a situation that allows for the exercise of the
COMELEC Chairman’ss power to augment actual
 MARMETO v. COMELEC 1. WON COMELEC is mandated to enforce and administer the
G.R. No. 213953 / SEP. 26, 2017 / DEL CASTILLO, J. / RECALL / laws on local
ZEDY initiative and referendum – YES
● (See notes for the discussion on the concept of initiative)
NATURE Petition for Review on Certiorari and ● The Constitution mandated the Congress to "provide for a system
Mandamus of initiative and referendum, x x x whereby the people can directly
PETITIONERS Engr. Oscar A. Marmeto propose and enact laws or approve or reject any act or law or part
RESPONDENTS COMELEC thereof by the Congress or local legislative body x x x."2 In
SUMMARY. Marmeto filed in behalf of the Muntinlupa People Power (MPP) a proposed compliance, the Congress enacted RA No. 6735 on August 4,
ordinance with the Sangguniang Panlungsod (SP) of Muntinlupa. The proposal sought 1989the which provided for a system of initiative and referendum on
creation of a sectoral council and the appropriation of the amount of ₱200 million national
for the and local laws.
livelihood programs and projects that would benefit the people of Muntinlupa City. ● SPSince
failed the LGC codified all laws pertaining to local
to act so Marmeto filed a petition to invoke initiative power under LGC. Comelec governments,
denied the provisions on local initiative and referendum
petition for lack of SP’s authority to enact such ordinance. Marmeto refiled proposed found in RA No. 6735 were reiterated, with slight modifications, in
ordinance with the newly constituted SP, which again remain unacted. Marmeto filed anotherSections 120 to 127 of the LGC; all other provisions in RA No.
6735 not inconsistent within the Sections 120 and 127 of the LGC
petition with Comelec. Comelec denied petition for alleged lack of appropriation to conduct
initiatives. SC ruled that the 2014 GAA appropriated funds to Comelec for the “conduct remained
and valid and in effect.
supervision of elections, referenda, recall votes and plebiscites,” which include the● conduct
RA No. of 6735 and the LGC are thus the pertinent laws on local
initiative
initiatives. Hence, funds were allocated for the purpose of conducting initiatives. However, SC and referendum which the COMELEC is mandated
affirmed Comelec’s dismissal of the first petition for lack of SP’s authority to enact the
to enforce and administer under Article IX-C, Section 2(1) of
proposed ordinance. SC ruled that: the Constitution.
(A) The creation of a separate local legislative body is ultra vires
(B) The sectoral council's proposed function overlaps with the Local Development 2. Council
WON COMELEC committed GAD for dismissing the second
(C) The LGC requires local government funds and monies to be spent solely forpetition public for alleged lack of budgetary allocation for its
purposes, and provides transparency and accountability measures to ensure this end conduct – YES
● SC discussed Goh v. Bayron and applied it to this case. (Dinelete
DOCTRINE. The term "election" in the GAA appropriation is comprehensive enough ko natoyung extensive discussion ng Goh kasi may digest naman
include other kinds of electoral exercises, including initiative elections. na tayo nung case)
● There is no reason not to extend the Goh ruling to the present
FACTS. case. In fact, Marmeto's second initiative petition was also filed in
● Marmeto filed in behalf of the Muntinlupa People Power (MPP) a 2014; in dismissing Marmeto' s petition for lack of funds, the
proposed ordinance with the Sangguniang Panlungsod (SP) of COMELEC was referring to its budget under the FY 2014 GAA.
Muntinlupa. The proposal sought the creation of a sectoral council ● Although Goh involved the conduct of recall elections, the ₱1.4
and the appropriation of the amount of ₱200 million for the billion appropriation under the FY 2014 GAA was for the "conduct
livelihood programs and projects that would benefit the people of and supervision of elections, referenda, recall votes and
Muntinlupa City. plebiscites."
● For failure of the SP to act on the proposition within 30 days from ● The term "election" is comprehensive enough to include
its filing, Marmeto filed a petition for initiative with the same body other kinds of electoral exercises, including initiative
to invoke the power of initiative under the LGC. (First Petition) elections. As earlier mentioned, the COMELEC's constitutional
● (Here’s how the petition ended up with the Comelec) The mandate is to enforce and administer all laws relative to the
secretary of SP of Muntinlupa wrote a letter to the COMELEC conduct of an election, plebiscite, initiative, referendum, and
stating that the proposal could not be acted upon by recall. The Constitution further states that the "[f]unds certified by
the Sanggunian because the City's budget for FY 2013 had the [COMELEC] as necessary to defray the expenses for holding
already been enacted. Thus, a new appropriation ordinance was regular and special elections, plebiscites, initiatives, referenda,
needed to provide funds for the conduct of the initiative. and recalls, shall be provided in the regular or special
● COMELEC issued Resolution No. 13-0904 (First Resolution) appropriations and, once approved shall be released
setting aside Marmeto's initiative petition because the automatically."3 Thus, the budgetary allocation for the "regulation
propositions therein were beyond the powers of of elections" identified as the COMELEC's MFO 1 should
the Sanggunian Panglunsod to enact and were not in accordance necessarily also cover expenses for the conduct of initiative
with the provisions of existing laws and rules. elections.
● Comelec denied Marmeto’s MR. Nonetheless, it noted that ● The Court also notes that, aside from the ₱1.4 billion
Marmeto might opt to re-file his initiative petition, since the then appropriation for the "conduct and supervision of elections,
newly-elected members of the Sangguniang Panlungsod of referenda, recall votes and plebiscites," the COMELEC was
Muntinlupa might be more sympathetic to Marmeto' s also given ₱1.6 billion in the FY 2014 GAA for the
propositions. "management and supervision of elections and other
● Marmeto filed a second proposed ordinance with the SP. Again, electoral exercises."
no favorable action was done by the Sanggunian within 30 days ● Thus, as in Goh , the COMELEC was provided with budgetary
from the filing of the proposal, prompting Marmeto file a second allocation for the conduct of initiative elections. The COMELEC,
initiative petition with the Office of the City Election Officer. therefore, committed grave abuse of discretion in dismissing
(Second Petition) Marmeto' s second initiative petition on the ground that there were
● On April 1, 2014, Marmeto filed a Supplemental Petition to comply no funds allocated for the purpose.
with the requirements of COMELEC Resolution No. 2300, which
provided the Rules and Regulations Governing the Conduct of 3. WON COMELEC has the power to review whether the
Initiative on the Constitution, and Initiative and Referendum on propositions in an
National and Local Laws. initiative petition are within the power of the concerned
● On July 22, 2014, the COMELEC issued the assailed Resolution Sanggunian to enact - YES
No. 14- 0509 (Second Resolution) which effectively dismissed ● (SC first discussed why it may rule upon this issue)
Marmeto's second initiative petition for lack of budgetary ● COMELEC: the propositions raised in Marmeto’s second petition
allocation, considering the absence of any provision in Comelec’s were matters that were not within the powers of the SP to enact.
FY 2014 budget for the expenses for local initiative or any other ● Marmeto: The arguments the COMELEC now raises were not the
election activity, that the power of local initiative cannot be grounds which the COMELEC cited in the Second Resolution
invoked by Engr. Marmeto will entail expenses on the part of the that is assailed in the present petition. He points that the second
Comelec. petition dismissed his second initiative petition solely for lack of
● Marmeto filed the present certiorari and mandamus petition.

2 Article VI, Sec. 32.

ISSUES & RATIO.
3 Art. IX-C Sec. 11.
 specific budgetary allocation. There was no mention in the
assailed resolution that the propositions in his second initiative
petition were not within the powers of the Sanggunian to enact.
This ground was instead cited by the COMELEC in its First
Resolution which dismissed Marmeto's first initiative petition.
Hence, he opines that the propriety of the propositions contained
in his second initiative petition, not being covered by the assailed
COMELEC resolution, cannot be reviewed in the present petition.
● SC: In several cases, this Court considered issues which
were not raised by either party when these issues are
necessary for the complete resolution of the cases. If the
Court can review unassigned errors which are necessary to arrive
at a just resolution of the case, with all the more reason can it
review a matter raised as a defense by a party to uphold the
validity of a resolution assailed in the case.
● (SC now discussed the issue itself)
● Section 124(b) of the LGC provides that "[i]nitiatives shall extend
only to subjects or matters which are within the legal powers of
the Sanggunian to enact." Section 127 of the LGC gives the
courts authority to declare "null and void any proposition
approved pursuant to this Chapter36 for violation of the
Constitution or want of capacity of the Sanggunian concerned
to enact the said measure." Significantly, the power of the courts
to nullify propositions for being ultra vires extends only to
those already approved, i.e. those which have been approved by
a majority of the votes cast in the initiative election called for the
purpose. In other words, the courts can review the terms only
of an approved ordinance. It will be premature for the courts to
review the propositions contained in an initiative petition that has
yet to be voted for by the people because at that point, there is no
actual controversy that the courts may adjudicate.
● This begs the question of which tribunal can review the
sufficiency of an initiative petition?
● Inasmuch as the COMELEC also has quasi-judicial and
administrative functions, it is the COMELEC which has the
power to determine whether the propositions in an initiative
petition are within the powers of a concerned Sanggunian to
enact.
● In SBMA v. Comelec, the Court ruled that -while regular courts
may take jurisdiction over 'approved propositions' per said Sec. 18
of R.A. 6735, the Comelec in the exercise of its quasi-judicial
and administrative powers may adjudicate and pass upon
such proposals insofar as their form and language are
concerned x x x and it may be added, even as to content,
where the proposals or parts thereof are patently and clearly
outside the 'capacity of the local legislative body to enact.' x
x x”
● The COMELEC's power to review the substance of the
propositions is also implied in Section 12 of RA No. 6735, which
gives this Court appellate power to review the COMELEC's
"findings of the sufficiency or insufficiency of the petition for
initiative or referendum x x x."
4. Marmeto 's propositions in his initiative petition are beyond
the powers of the Sanggunian Panlungsod ng Muntinlupa to
enact – YES
● Marmeto's initiative petitions propose the following:
(1) The creation of a sectoral council composed of 12 members
from various sectors who will serve as the people's
representatives for the implementation and management of
livelihood programs and projects;
(2) The sectoral council will also stand as the people's
representatives that will directly propose, enact, approve, or
reject ordinances through initiative or referendum;
(3) An appropriation of ₱200 million to be allocated for livelihood
projects of the people and other purposes. The net income
from the projects will then be used for the delivery of basic
services and facility for Muntinlupa residents;
(4) The MPP will create the implementing guidelines and
procedure for the utilization of the appropriated funds, and
conduct programs and project feasibility studies. It shall
comply with the prescribed accounting and auditing rules of,
and submit monthly accomplishment report to the local
government unit (LGU). It shall also observe transparency
and accountability in fund management.
● These propositions, however, are either sufficiently covered by or
violative of the LGC for reasons explained below.
● (A) The creation of a separate local legislative body is ultra
vires
o Under the LGC, local legislative power within the city is to be
exercised by the Sangguniang Panlungsod,4 which shall be
comprised of elected district and sectoral
representatives.5 The sectoral representatives, moreover,
shall be limited to three members, coming from
enumerated/identified sectors.6
o Significantly, nothing in the LGC allows the creation of
another local legislative body that will enact, approve, or
reject local laws either through the regular legislative
process or through initiative or referendum.
o Even Marmeto's claim that the sectoral council will not
legislate but will merely "facilitate" the people's exercise of
the power of initiative and referendum is rendered
unnecessary by the task the COMELEC must assume under
the LGC. Section 122(c) of the LGC provides that the
COMELEC (or its designated representative) shall extend
assistance in the formulation of the proposition.
● (B) The sectoral council's proposed function overlaps with
the Local Development Council
o The LGC requires the establishment in each LGU of a local
development council, whose membership includes
representatives of POs/NGOs operating within the
LGU.7 These local development councils are primarily tasked
with developing a "comprehensive multi-sectoral
development plan"51 in their respective LGUs. City
development councils are specifically tasked to exercise the
following functions:
(1) Formulate long-term, medium-term, and annual
development plans and policies;
(2) xxx;
(3) Appraise and prioritize socio-economic development
programs and projects;
(4) x x x;
(5) Coordinate, monitor, and evaluate the implementation
of development programs and projects; and
(6) Perform such other functions as may be provided by
law or competent authority.
o Given these functions of the city development council,
there is a clear overlap with those proposed by Marmeto
to be performed by the sectoral council and/or MPP.
● (C) The LGC requires local government funds and monies to
be spent solely for public purposes, and provides
transparency and accountability measures to ensure this end
o The Court finds disturbing in Marmeto' s initiative petitions
the authority of the proposed sectoral council to utilize,
manage, and administer public funds as it sees fit.
o The fundamental principles in local fiscal administration
provided in the LGC state that no money shall be paid out of
the local treasury except in pursuance of an appropriations
ordinance or law,8 and that local government funds and
monies shall be spent solely for public purposes.9
o Marmeto' s petition proposes the appropriation of ₱200
million for the livelihood programs and projects of Muntinlupa
residents. Significantly, the utilization of this amount is
subject to the guidelines to be later implemented by
Marmeto's MPP. That these guidelines will be drafted
and implemented subsequent to the initiative elections
denies the Muntinlupa residents of the opportunity to
assess and scrutinize the utilization of local funds, and
gives Marmeto and his organization an almost complete
discretion in determining the allocation and
disbursement of the funds. It is no justification that the
4 Sec. 48.
5 Sec. 41, (a) and (b).
6 Sec. 41, (c).
7 Sec. 107.
8 Sec. 305, (a).
9 Sec. 305 (b).
 funds will be used for public purposes on the claim
these will be applied to programs and projects that will
eventually redound to the benefit of the public.
o Our laws have put in place measures to ensure
transparency and accountability in dealing with public
funds,10 since "[p]ublic funds are the property of the
people and must be used prudently at all times with a
view to prevent dissipation and waste."11 These
measures may be subverted or rendered inapplicable when
the management and utilization of the funds is turned over to
private persons or entities.
o Although comprised of Muntinlupa residents and voters,
Marmeto' s MPP remains a private organization and its
members cannot be considered as public officers who
are burdened with responsibility for public funds and
who may be held administratively and criminally liable
for the imprudent use thereof.

DECISION.
Petition denied.

NOTES.
● Initiative has been described as an instrument of direct
democracy whereby the citizens directly propose and
legislate laws. As it is the citizens themselves who legislate the
laws, direct legislation through initiative (along with referendum) is
considered as an exercise of original legislative power, as
opposed to that of derivative legislative power which has been
delegated by the sovereign people to legislative bodies such as
the Congress.
● Section 1 of Article VI of the Constitution recognizes the
distinction between original and derivative legislative power by
declaring that "legislative power shall be vested in the Congress x
x x except to the extent reserved to the people by the provision on
initiative and referendum." The italicized clause pertains to the
original power of legislation which the sovereign people have
reserved for their exercise in matters they consider fit.
Considering that derivative legislative power is merely delegated
by the sovereign people to its elected representatives, it is
deemed subordinate to the original power of the people.

10 Presidential Decree No. 1445 or the Government Accounting Code of the

Philippines, and Sections 335 to 354 of the LGC.
11 Yap v. Commission on Audit, 633 Phil. 174, 188 (2010).