Mandanas v.

Ochoa 
GR NO.199802  | Date: July 3, 2018
Ponente: BERSAMIN, J.

Facts: To implement the constitutional mandate for decentralization and fiscal

autonomy, Congress enacted the Local Government Code (LGC) in order to guarantee
as such. In Sec. 284 of the said law, it provides that Local Government units shall have
a just share in the internal revenue taxes. Assailing the constitutionality of the said
provision, two cases have been filed. In Mandanas, et al., the petitioner assails the
manner the general appropriation act (GAA) was computed while in G.R. No. 208488,
the sole petitioner, Garcia, seeks the writ of mandamus to compel the respondent
thereat to compute the just share of the LGUs on the basis of “national taxes,” as given
in the Constitution. On October 22, 2013, the two cases were consolidated, and the
following issues were addressed by the court. 

Issue: Can the LGUs’ just share in the national taxes be automatically released without
the need of an appropriation?

Ruling: Yes. It shall be automatically released without the need of an

appropriation.
Sec. 6, Article X of the Constitution provides that the just share of the LGUs in the
national taxes shall be automatically released to them. Corollary to that, Sec. 286 of the
LGC provides the automatic release of share of each local government unit without
need of any further action. In the case at hand, the court ruled that the inclusion of the
just share of the LGUs in the annual GAAs is unnecessary, if not superfluous, since
Congress have already established the just share through the LGC. Hence, the just
share of the LGUs in the national taxes shall be released to them without need of yearly
appropriation.