PROVINCE OF BATANGAS v. ROMULO
Re: Principle of Local Autonomy
FACTS: Petitioner filed a petition to declare as unconstitutional and void certain provisos contained in the General Appropriations Acts (GAA) of 1999, 2000 and 2001, insofar as they uniformly earmarked for each corresponding year the amount of five billion pesos (?5,000,000,000.00) of the Internal Revenue Allotment (IRA) for the Local Government Service Equalization Fund (LGSEF) and imposed conditions for the release thereof.
ISSUE: WON said provisos violate the constitutional precept on local autonomy.
HELD: Yes. The Constitution (Sec. 6, Art X) and the LGC 1991 (Sec. 18) explicitly provides that LGUs shall have a just share, as determined by law, in the national taxes which shall be automatically and directly released to them without need of further action. Hence, the provisos imposing conditions for the release of LGU funds are unconstitutional.
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