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DOS and DON'TS UNDER THE BAYANIHAN ACT

● LGUs are in the frontlines.


● LGUs are in the Middle People <——- >LGU <————->State
○ Institutional Frontliners: lie between two principals
○ Development Partners
○ Respond to needs of people
● “Breaking quarantine directives is breaking the law.”
○ Prohibition from LGU to impose mandatory testing
○ Establish bike lanes
○ Wear face masks
● What is the effect if LGU violates DILG circulars?
● Ordinances /Executive Orders
○ Can a mayor Issue EO without an ordinance?
■ State of Calamity
■ Quarantine
■ Hard lockdown
■ Closure of Lockdowns
■ Anti Hoarding
■ Liquor Ban

FUNDAMENTAL QUESTIONS
1. Are the DOs and DON'TS for LGUS today shaped by DILG/IATF?
a. YES.
2. Under the Bayanihan Heal as One, can the DILG preempt the actions of LGU and direct
their policies?
a. YES. under the extraordinary times.
3. Is this or will this be the norm or is this the current new normal?
a. NO. ​Not the norm but the current normal during extraordinary times. Only during
the pandemic.

TOPICS
1. Nature of LGUs
a. In amending the Bayanihan Act, can Congress add sitios as a local government
unit?
i. NO. List of LGUs (5-​ Autonomous Regions, provinces, cities,
municipalities, barangays)
ii. The Constitution provides for an exclusive list.
iii. Congress by ordinary legislation cannot add or subtract to this.
b. Can the President or Congress, through EO, provide for the federal set-up?
i. No. ​We are under unitary. If we are going to shift to federal where state
have claims against a state, this had to be done through ​constitutional
revision.
c. Can Congress, in amending the 1991 LGC, mandate that governors preside over
sessions of Sangguniang Panlalawigan?-Yes
i. W/N separation of powers also apply to local governments?-
Qualified Y ​ es
1. No system of separation of powers for local governments
2. What determines delineation-> Congress.
d. Can an incumbent mayor cancel the contract entered into by the previous
mayor? - No. Corporate succession, M ​ ayor only signs the contract as
representative of LGU.
e. Can a city enter into a public-private partnership for its market? Tax collection? -
Yes for market, proprietary function. Tax collection is a governmental function.
Cannot be shared/delegated to the private sector.

NATURE OF LGUS
● LGUs are admin agencies performing several functions.
○ Municipal and territorial in nature.
○ Unit belonging to the state.
○ Twin capacities- Double agents of state and people.
○ Frontliners- Better position to address and ascertain needs of constituents.
○ Separation of powers under the law ​NOT CONSTITUTION.
○ Creation of legislature. ​they cannot be created by the executive branch.
○ Juridical persons: sue and be sued
○ Right of succession: Corporate entity subsist notwithstanding the changes in
administration

2. Local Autonomy
a. Is Local autonomy = self governance
i. Not absolute self governance. ​It is Q ​ ualified self governance.
b. Can DBM impose a cap on the allowance of cities may give to judges
i. No cap. ​Allowance is dependent on the financial capability of the LGU.
DBM, absent a law imposes a cap, cannot impose a cap since amount to
legislation and control and infringe in the local autonomy of LGU.
c. Can LGU incorporate a subsidiary/quasi-municipal corporation
i. It depends.
1. Liberalist:
2. Centrist:
d. Can a provincial legislative council grant franchise to a cable TV operator
pending the issuance of a franchise by Congress?
i. No. ​The granting of cable TV franchise remains with NLRC. It is not a
devolved power, not transferred to LGUs. To do so is void.
e. Are you a liberalist or centrist?
Left Right

LGUs can exercise those powers given to Only those powers given to them
them and those that are not prohibited by law

(more innovative, more risks)


● subsidiary- can be done not no. not expressly allowed
prohibited.

LGUs action must not be inconsistent with Must be consistent with law.
laws.

Liberal Centrist

LGUs can exercise those powers only those expressly given

1. Expressly given implied and necessary to perform exoress


powers

1. Implied qnd necessary

3. not otherwise prohibited by law for gen


welfare

LOCAL AUTONOMY
● more responsive and accountable local government structure instituted through a system
of decentralization.
● Restricted by constitution.
● Subordinate legislation: Local autonomy is not a pass to violate the law.
● 6Ds
○ DECENTRALIZATION:

Of Admin Of power

Delegation of Admin powers (regulatory and Abdication of political powers


basic services)

Relieves State from burden of managing local Free to chart its own destiny, self immolation
affairs

Executive supervision Executive supervision, minimal state


intervention
Dual agency ( state and people) Greater accountability to people (self
determination)

Provinces, cities, municipalities, barangays Autonomous regions

○ Devolution: powers from NG, GOCCs, instrumentalities


○ Deconcentration: from central to field office

Administrative Political

Deconcentration Devolution

Unspecified powers Power specific ​(if not given to LGU, it remains


with the National Government)
● Granting of franchise for tricycles
● Cockfighting
○ Temporarily withdrawn by
Bayanihan Act.
○ DILG has issued circulars
prohibiting tricycles and
cockfightings despite powers
being devolved to LGUs.

Transfer from NGA to NGA Regional Offices Transfer from NGA to LGU

Administrative Regulatory Powers, Basic Services, Assets


and Personnel

Sec. 528, 1991 LGC Sec 17, 1991 LGC and other statutes.

○ Delegation
○ Discretionary powers
○ Democratization: give ordinary citizens to participate in local governance
● Does not contemplate making mini-states or impenetrable states out of LGU.
● is either ​decentralization of administration or decentralization of power.
● Means that absent a law, ​NGA cannot limit/restrict discretion of LGU/ impose
requirements
○ Only Congress can limit the powers of LGUs.
○ Under the Bayanihan Act, this is not the case.
■ Without specific law, national government can limit the LGUs bu defining
do and don’ts.
● Give LGUs discretionary powers and allows diversity
○ Ordinary times: cannot be limited
○ Bayanihan Act: Discretion of LGUs are limited.
■ They know best how to address their local concerns but under the Act,
national government knows best.
● Acknowledges superior competence of LGUs in addressing local affairs.

3. Supervision and Control


a. EXECUTIVE SUPERVISION: ​The DOJ
i. CAN declare a tax ordinance illegal
1. Question of law, part of supervision.
ii. CANNOT declare a tax ordinance excessive
1. Question of fact
iii. CANNOT direct the city to lower the real property taxes
1. Amount to control, substitution of judgment of lgu
iv. CANNOT Declare illegal a fee measure
1. police powers of lgu
2. review powers of doj
a. tax ordinance
b. whether lawful or ultra vires- only to tax, not fee
b. LEGISLATIVE CONTROL: ​The Congress, in amending 1991 LGC
i. Provide the vice mayors shall be appointive officials
1. Yes, under cons, it is up to congress to determine qualification of
officials. Vice mayors are not in cons, sole creation by Congress
therefore they can prescribe qualification
ii. Require that governors must be college graduates
1. Yes. Qualification is up to Congress
2. Not the same for senator and Congress because it is found in
Constitution
iii. prescribe a proportional representation scheme for electing lgu officials
1. Yes. Manner by which local government officials are elected or
selected is dependent on Congress.
iv. CANNOT state that lgu shall share from collection of bir
1. IRA
2. LGU have been deprived of share in National Taxes- not limited to
collected by BIR
v. empower dilg to exercise control over lgus and to review ordinances
1. Extraordinary times, DILG has control over LGUs.
c. Organizational Hierarchy
i. DIRECT: ​President to BAR (Bangsamoro), Provinces and Cities in Metro
Manila; provinces to component cities
ii. INDIRECT: Provinces to barangays
1. A province cannot suspend a punong barangay- does not have
direct supervision over barangays. It is only city/municipality that
has direct supervision over the barangay.

d. Supervision v. Control
i. Supervision- executive branch
1. Power of dbm impose a cap- no, no limit
2. DOJ declare illegal- Yes but it cannot change the decision of LGU,
3. Only two national agencies given by congress power to declare
illegal ordinances: DOJ (tax), DBM (appropriation ordinances)
ii. Control- Legislative
1. The president has no control over LG.
a. Only power is one of supervision.
b. Acts of Control-
i. power to change,
ii. preempt
iii. limit the discretion
iv. impose limitations.
c. In Bayanihan Act, DILG imposes control over LGUs
i. Cockfighting, tricycles.
ii. Devolved powers which are temporarily withheld.
iii. Supervision v Control
1. Executive supervision
a. Province can declare illegal an ordinance of component
city
b. Can discipline erring mayor
2. Legislative control
a. Up to congress to determine elective and appointive
officials for LGUs
b. They can change, modify qualifications
c. National Tax share must be just.
3. EXECUTIVE CONTROL
a. Generally prohibited but there are two found in 1991 LGC
i. DOH: health operations in LGUs for duration of
epidemics,pestilence and other widespread disease
ii. RA 11332: Mandatory reporting of notifiable
disease
iii. DENR: Implementation of community based
forestry
b. In these two instances, NG has control over LGU
notwithstanding the fact that Cons only provide for
supervision

4. Conflict-Resolution: ​How do we resolve conflicts


a. Statements
i. The DOJ issues an unpublished legal opinion saying that conflicts
between Bayanihan Act and LGC must be resolved in favor of the former.
1. TRUE. ​Provision in Bayanihan Act.
ii. City Legislative bans the establishment of lotto outlets
1. FALSE. ​Effectively amend the charter of PCSO which has specific
mandate.
2. It can regulate the physical set-up of lotto outlets in terms of
enforcing national building code.
iii. MMDA directs private subdivisions to allow non residents to use their
roads
1. FALSE. ​MMDA has no police power. It is not a LGU and has no
power to legislate.
iv. The LLDA, contrary to the ordinance of lakeshore LGUs, orders the
demolition of fishpens
1. TRUE.
2. LLDA exercise integrative functions- covers issues which is cross
boundary (affect several boundaries)
3. Principle of integration prevails.
v. The city allows the construction of a photobomber building.
1. TRUE
2. Manila City did not violate any law
3. PRINCIPLE OF SUBSIDIARITY. ​Manila City has superior
competence in terms of addressing local concerns.
b. Example of cases deciding conflicts in favor of National Government of LGU
i. DEFAULT: Follow law:
1. If no law, ​national dimension rule​ (cross boundary) or
municipal dimension rule (only territory, LGU will prevail)
2. Under the Bayanihan Act, everything covered by Bayanihan
Act- we follow national dimension rule.
a. All issues pertaining to COVID is national in nature,
b. Conflict between local and national: national will prevail.
ii. In favor of NGA if:
1. Integration
2. Centralization
3. Avoid fragmentation
4. Mandate exclusive under charter/law
5. Implied repeals not favored
6. Instrumentalities of the State
7. National or cross boundaries
iii. In favor of LGU if:
1. Local autonomy
2. Local concern/issue
3. “isolated issue”
4. No law will be violated
5. As agents of communities
6. Amounted to Executive Control
7. Express repeal; Conclusive implied repeal
8. Beyond power of NGA/GOCC/GI
9. Local concerns are best addressed by LGUs (Principles of
subsidiarity and stewardship, superior competence)

5. Bayanihan Act
a. Questions:
i. Does the Bayanhian act give the ​President all
emergency/extraordinary powers ​allowed in the 1987 Constitution?
1. NOT ALL.
a. Only two powers
i. Emergency powers
1. Declared national policy (covid 19)
a. National emergency, of lives and
economic activities.
ii. Powers to take over private establishments
2. Under the ​faithful execution clause,​ President is duty bound to
follow the law, the Bayanihan Act which is a temp measure.
3. Life of Bayanihan Act is only three motnhs.

ii. Can the Bayanihan Act be ​perpetualized​?


1. No​. It will expire June 25. The life of Bayanihan Act is only for
three months and this took effect March 26.
2. Absent any amendment, it will be back to normal.
iii. Can Congress provide for penalties in violation of the Bayanihan Act?
1. Yes. ​there is penal provision under the Bayanihan Act.
2. LGUs who disobey can be penalized with a fine or imprisonment.
3. Section 6 pertaining to penalties., Section 7: Construction in favor
of Bayanihan Act

6. Enhanced Supervision
a. Intro
i. The DILG, through a memo circ addresses to all LGUs which was not
posted in ONAR, mandates that LGUs cannot impose prior testing to
returning workers
1. YES. LGUs cannot impose prior testing as mandated by DILG.
ii. A provincial council, through an ordinance, imposes a province wide GCQ
contrary to pronouncement of IATF of placing it under ECQ
1. NO, it cannot provide for a lower ​level quarantine but it can
provide for stricter levels of quarantine.
iii. The Bayanihan Act allows enhanced supervision and some aspects of
executive control
iv. The Bayanihan Act amends some provisions of LGC
1. YES. ​Although temporarily, it amends provisions of LGC
a. Tricycles, cockfighting, traffic management, collection of
taxes, emergency procurement, government procurement
reform act.

b. Section 4(G) of Bayanihan Act


i. Two sets of activities
1. Defined: National Government
a. Who defines: ​President through IATF, National
Government Agencies, GOCCs and GIs.
2. Undefined: LGU
3. Administrative relationship
a. Ordinary times
i. Executive no control, only Congress has control.
ii. Executive only has supervision
b. Extraordinary times
i. Some aspects of control that NG can exercise
c. Uniformity
i. Follow national governments otherwise might be
penalized.
ii. DILG can preempt powers.
iii. LGU discretionary powers has been limited
d. 30th anniversary of LGC:
i. October 10, 2020
ii. Signed into law by Pres. Cory Aquino: October 10.
1990.
7. Powers of LGU (During normal times)
a. Questions
i. Direct closure of all beer houses along a street to curb prostitution
1. NO. ​While legal purpose, means is illegal. All beerhouses can be
closed if owners will be paid just compensation.
2. It is an invalid police power but can be a valid exercise of eminent
domain.
3. ONE BEERHOUSE- Yes, after due process requirements have
been complied.
a. Because permits issued are mere privileges. They can be
revoked for violations of conditions attached in the permit.
ii. Impose a curfew for minors
1. YES. ​The Constitutional rights of minors must be protected.
iii. Declare a gas station nuisance per se
1. NO. ​Gas stations are not a nuisance by their very nature.
iv. Refuse to issue Mayor’s permit
1. YES​ because this is discretionary.
v. Issue cease and desist order
1. YES, ​lack of ECC.
vi. Prescribe stricter requirements than those in National Building Code
1. YES, ​police powers.
vii. Prohibit rallies/ Regulate rallies
1. NOT PROHIBIT: ​Freedom of speech
2. ONLY REGULATE: ​in terms of issuance of permits.
viii. Ban lotto outlets? Impose safety requirements?
1. CANNOT BAN BUT IMPOSE SAFETY REQUIREMENTS
ix. Regulate professions
1. NO.​ They can only regulate establishment of securing business
permits
x. Identify residential and commercial zones
1. YES.
b. Menu of powers of local governments
i. Police power
1. Why/purpose
a. Lawful subject
i. General welfare
ii. Quality of life
iii. Health, safety and morals
2. How/means
a. Lawful means
i. Regulate, prohibit
ii. Prohibit
iii. Restrict
iv. Taking not compensable
3. Basis: GENERAL WELFARE CLAUSE.
a. General welfare clause is the delegation in statutory form
of police powers of the State to LGUs.
b. NORMAL:​Classified into two
i. GENERAL LEGISLATIVE:
1. What is given under the law?
ii. POLICE POWER:
1. Not expressly given but necessary for
health, safety, prosperity, morals.
c. BAYANIHAN ACT
i. GENERAL LEGISLATIVE
1. Increasing number of activities which are
now defined.
2. Has been expanded
ii. POLICE POWER
1. Undefined has been constricted.
2. Limited.
ii. Eminent Domain

iii. Devolved power


iv. Residual power
v. Legislative power
vi. Supervisory power
vii. Revenue-raising power
1. In order for them to perform their functions, they must have money
2. Incident of Fiscal Autonomy
3. Constitutional Sources
a. Taxes
b. National Tax Allotment
c. Share in National Wealth
d. Fees and charges
e. Other sources.
4. Statutory sources
a. Loans
b. Grants
c. PPP
d. Bonds and debentures
5. Sources not exclusive, residual power
viii. Executive power
ix. Corporate power
1. Corporate succession
2. Use corporate seal
3. Sue and be sued
4. Acquire and convey property
5. Enter to contracts
6. Others

8. Local Legislation/Executive Power


a. Statements
i. A Municipal Legislative Council conducts three readings in one day
1. Yes. No prohibition, then allowed.
ii. Mayor issues EO without enabling ordinance, imposing a liquor ban and
providing for community service for violators.
1. Qualified yes.
a. EOs can be issued to enforce a law.
b. EOs are presumed valid but can be questioned.
c. Must follow rules on subordinate legislation.
i. Not inconsistent with Constitution, charters,
statutes and local ordinances.
d. can be issued for a ​stop gap ​or emergency measures.
e. If allowed by national government agencies.
iii. A Mayor recalls business permits for violation of the municipal curfew
ordinance
1. Yes. ​Business permits are privileges which can be withdrawn after
compliance with due process for violations of conditions.
iv. A Sangguniang Panlalawigan cites a person in contempt during a public
hearing
1. No.​ In order for an admin agency like LGU to cite a person in
contempt, power must be expressly given to it by Congress
2. Power still withheld from LGUs.
b. Rules for Local Legislation
i. Delegated
1. Constitution and law
ii. Subordinate
1. Implied restriction
iii. Denominated
1. Proper procedures
iv. Derivative
1. From people; initiative
v. Enjoys Presumption
1. Subs and proc
vi. Formal
1. Ordinance or resolution
vii. Prospective/Operative Fact
viii. Subject to Veto and Review
ix. Subject to Admin/Judicial Review

c. DILG
i. 66 circulars to date preempting/imposing directives to LGUs.
ii. Defined the defined areas limiting police power proper
iii. Sample circulars (IMPT to look at date)
1. Quarantine
a. Testing procedures priority
b. Imposition of the Window period has been disallowed.
c. Checkpoints supervised by police
d. Passes must be free of charge
e. No voter no access cannot be imposed
f. Limiting benefits to voting residents is not allowed
g. Anti-Epal of relief goods not allowed
h. Mass gatherings is still prohibited
i. Cockfighting is banned.
2. Cycling- not issued.
3. Facemasks
4. Public transport
a. Tricycles- amendment to LGC
5. Unhampered movement of cargos
6. Returning OFWS/LSIs.
a. Must assist and cannot deny entry
7. Collection of taxes has been suspended.
8. Funds
a. special education cannot be used for covid
b. peace and order can be used.
c. Local development can be used
9. Budgets
a. Supplemental budgets can be passed
10. Allowance
a. Special risk allowance is dependent on capacity of LGU
11. Facilities
a. National Governments not LGUs are authorized to take
ofer
b. Hotels cannot be opened by LGUs.
iv. Quarantine orders issued by LGUs
1. Cotabato: time restriction on pass, odd even scheme, sundays no
movement, skeletal workforce, violations are penalized under RPC
2. QC: prohibited activities (mass gatherings, physical classes, public
transpo exc tricycles), require pass to enter city, community
testing, limited ingress, egress, violation: charges for violation of
RA 11332 and RPC (resistance to person in authority)
3. Abra: Decontamination chambers
4. Ilocos Norte: total lockdown with exceptions, closure, checkpoints,
passage requirements
5. Cebu: prohibit entry of domestic passengers via air travel
6. Total lockdowns (Manila)
7. Curfew (Makati, Cebu)
8. Mall closure (Mandaluyong, Caloocan)
9. Anti-Discrimination (​Mandaluyong, Caloocan)
10. Liquor Consumption
11. Anti hoarding
12. Tricycles
13. Adoption of Higher LGU
a. Component municipalities must Follow lead of supervising
provinces
14. Contracts
a. Blanket Authority to enter tocontract.

9. Accountability and Liability


a. Questions
i. Can DILG order the removal of the governor for violating a DILG memo?
1. NO. ​The DILg can only investigate, cause the filing of a complaint
BUT they cannot remove.
2. Only courts can remove erring local officials
ii. A Sangguniang Panlalawigan suspends an erring barangay
1. NO. ​Sangguniang Panlalawigan only exercises indirect
supervisions over barangays.
iii. Provincial Governments are immune from suit
1. NO. ​Local governments can sue and be sued
iv. A mayor can be recalled this December
1. YES. ​Under the LGC, local officials can be recalled during the
second year of their three year term. (2019-2022)
b. Liability
i. Corporate v Personal
1. As juridical persons
2. Officials can also be disciplined- maximum penalty: one of
suspension.
a. ONLY courts can remove erring officials.
ii. Suability v Liability
iii. Disciplining v Investigating
iv. Administrative v Juridical
v. Suspension v Removal v Recall
vi. Penalty v Preventive
10. OPEN FORUM
a. Can an LGU through an ordinance, adopt and impose the mandatory use of
covid 19 contract tracing application within its territorial jurisdiction?
i. Yes. Go over DILG circular. As of now, no guideline and this will fall under
undefined area therefore LGUs are free to adopt their own regulations so
long as consistent with policies of IATF.
ii. But if they become defined, they must follow regulation.
1. Example mandatory testing of returning workers.
2. Was converted from undefined to defined.
b. IATF has been micro managing the affairs of LGU and is inconsistent with
LGU-led, NG-enabled.
i. As an academic, the enhanced supervision concepts.
ii. There are certain aspects of control which are present.
1. NOT present:National government changing the decisions of
officials.
2. However in case of violation, expect show cause order. -
preemptive.
c. Can an LGU executive require Covid 19 swab test, med certs and quarantine
before allowing entry back into its jurisdiction?
i. Yes. ​Circular pertaining to LSI.
ii. Agent of people: w ​ ithout specific restrictions, this is in pursuit of
emergency powers/police powers
d. If the LGU cannot require returning workers or helpers to undergo covid tests and
quarantine before workers go back to the house to work, then who will impose
the rules on returning workers? the DOH?
i. Either DOH or DILG. This will now become defined.
ii. GR: If not defined, LGU is allowed.
e. What is the function of the IATF is Bayanihan is not extended before June 25,
2020
i. The IATF was created prior to Bayanihan Act, its creation was affirmed by
Bayanihan Act.
1. IATF will become ​functus officio
2. IATF because it was created prior, the President needs body to
make collegial decisions: ​can become ad hoc body, ​under the
control of President. It has a life of his agency,
ii. With lesser teeth.
f. What are the powers of DILG over the MILG of the BARMM and the MILG over
LGUs in BARMM?
i. The DILG, in their circulars, covers the BARMM.
ii. BARMMs is still under the supervision of the President and although it
enjoys a higher level of local autonomy, the safe answer, regardless,
must still follow the DILG.
g. The Bayanihan Act declared a national emergency over the country. Also, there
is a declaration of a State of calamity throughout the Philippines. In line with this,
LGUs have the option to enter into negotiated procurement. Up to when can the
LGUs exercise this option? Also can the LGUs use this option in procurement of
services and goods not related to covid?
i. Under the Government Procurement Reform Act, even outside an
emergency situation, negotiated procurement is allowed.
ii. Now, because of the emergency, rules have been liberalized.
iii. The only limitation that it should be used in procurement of services and
goods related to covid is only when you use Bayanihan Grant to Cities
and Municipalities.
iv. What is relaxed is covid related expenditures.
h. Once Bayanihan ceases to be effective, does this mean that all IATF guidelines
and DILG circulars become unenforceable? Sanctions on violations should not
be imposed upon LGUs anymore?
i. If you look at effectivity clauses of circulars: no mention of having definite
periods. No mention of expiration.
1. If power of DILG to exercise some form of control is premised on
Bayanihan Act
a. Once it expires, aspects of control/enhanced supervision
also expires.
b. Preemptive powers will also expire
i. Can the Sangguniang Bayan compel the Local Chief Executive to submit copies
of disbursement vouchers of the Bayanihan Act for transparency? Prior to
submission to COA.
i. Compel- ​You can compel but no teeth. (cannot penalize).
1. All ordinances must be approved by the mayor, otherwise it will
not become law.
2. Sangguniang Bayan have no coercive power- cannot issue
subpoena, cite person in contempt.
3. Relief: ​Every LGU must account their expenditures through the
DILG
j. Can LGUs impose liquidated damages on contracts that lapsed already? And
can suppliers use the Bayanihan Act as ​force majeure ​to extend contracts and if
yes, until when is this allowable?
i. Liquidated damages. Dependent on terms of contracts itself. We have to
see what the issuances are.
ii. Force majeure-
1. Ordinary understanding: N ​ ever included pandemics like this.
2. Depending on the wording of the clause. If too broad, might be
justifiable.
k. ECM
i. Difficulty of LGUs.
1. Frontliners and have many responsibilities.
2. Suspension of collection of taxes: Taxes compose 70% of their
revenues.
3. No clarity if it will be reimbursed,
4. Genuine local autonomy depends on fiscal autonomy.
a. If there are no resources, tendency is to become
dependent.
b. Crisis will not end on June 25 but law will end.

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