GARCIA VS.

MATA
G.R. No. L-33713, July 30, 1975, 65 SCRA 517

Petitioner-Appellant: EUSEBIO B. GARCIA

Respondents-Appellees: HON. ERNESTO S. MATA, Secretary of National Defense, and GENERAL
MANUEL T. YAN, Chief of Staff, Armed Forces of the Philippines

FACTS

Garcia was a reserve officer on active duty who was reversed to inactive status. He filed an
action for mandamus to compel the DND and AFP to reinstate him to active service and
readjust his rank and pay emoluments.

Garcia claims that his reversion to inactive status is a violation of RA 1600 which prohibits the
reversion of officers with at least 10 years of service.

On the other hand, the AFP and DND contend that the said provision of RA 1600 has no
relevance or pertinence to the budget in question or to any appropriation item therein. RA
1600 was an appropriation law for 1956-57.

ISSUE

Whether or not RA 1600 is valid?

HELD

The incongruity and irrelevancy are already evident. Section 11 of RA 1600 fails to disclose the
relevance to any appropriation item. RA 1600 is an appropriation law for the operation of
government while Section 11 refers to a fundamental governmental policy of calling to active
duty and the reversion of inactive statute of reserve officers in the AFP.

Hence it was A NON-APPROPRIATION ITEM INSERTED IN AN APPROPRIATION MEASURE, in

violation of the constitutional prohibition against RIDERS to the general appropriation act. It
was indeed a new and completely unrelated provision attached to the GAA.

It also violates the rule on one-bill, one subject. The subject to be considered must be
expressed in the title of the act. When an act contains provisions which are clearly not
embraced in the subject of the act, as expressed in the title, such provisions are void,
inoperative and without effect.

SECTION 11 is unconstitutional. Garcia cannot compel the AFP to reinstate him.

Prepared By: Cheryl Durana Fenol

G. LEGISLATIVE DEPARTMENT (Article VI)
Section 25, #43 Garcia v. Mata 65 SCRA 517