Sumpay Law Office

12/01/2026

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30/12/2025

G.R. No. 274778, Aquilino Pimentel III et al. v. House of Representatives et al.
G.R. No. 275405, Bayan Muna Chairman Neri Colmenares et al. v. Executive Secretary Lucas P. Bersamin et al.
G.R. No. 276233, 1Sambayan Coalition et al. v. House of Representatives et al.

The , during its session on December 3, 2025, unanimously ordered the return of PhilHealth funds previously transferred to the National Treasury in the amount of PHP 60 billion and permanently prohibited the transfer of the remaining PHP 29.9 billion fund balance.

In a Decision penned by Associate Justice Amy C. Lazaro-Javier, the Court En Banc, by a majority vote, also declared void Special Provision 1(d), Chapter XLIII of the 2024 General Appropriations Act (2024 GAA), and Department of Finance (DOF) Circular No. 003-2024 for having been issued and implemented with grave abuse of discretion amounting to lack or excess of jurisdiction.

Special Provision 1(d) authorized the return of the fund balance or the excess reserve funds of government-owned or controlled corporations (GOCCs) to the National Treasury to fund unprogrammed appropriations under the 2024 GAA.

The DOF issued Circular No. 003-2024, directing the transfer of PHP 89.8 billion to the National Treasury, representing the fund balance or excess reserve funds of the PhilHealth. In compliance, the PhilHealth remitted PHP 60 billion to the National Treasury in three tranches.

The SC issued a temporary restraining order (TRO) against the transfer of the remaining PHP 29.9 billion PhilHealth funds and the further implementation of Special Provision 1(d) of the 2024 GAA and DOF Circular No. 003-2024.

The SC struck down Special Provision 1(d) of the 2024 GAA for being a rider—a provision not germane or related to the bill’s purpose. The Constitution requires all provisions of the GAA to be germane to its purpose to prevent surprise or fraud upon the legislature and to fairly inform the people of the bills’ subject.

While Special Provision 1(d) is particular in that it relates to the unprogrammed appropriations in the GAA, the Court found the provision ambiguous because it introduced the concept of a “fund balance”—a term not defined in the 2024 GAA.

The SC also ruled that Special Provision (1)d is unconstitutional because it impliedly repeals Section 11 of the Universal Health Care Act (UHCA) and the Sin Tax Laws.

The SC ruled that reallocating PhilHealth’s supposed “excess reserve funds” through Special Provision 1(d) and DOF Circular No. 003-2024 makes compliance with Section 11 impossible as they undermine the very nature of PhilHealth funds as pooled resources for social health insurance, among others.

The SC stressed that Congress cannot repeal Section 11 through the General Appropriations Act.

The SC further found that Special Provision 1(d) contradicts the Sin Tax Laws, which earmark specific percentages of excise taxes on sweetened beverages, alcohol, and to***co products exclusively for the UHCA.

The SC also ruled that the Finance Secretary cannot, in any capacity, augment any item in the GAA because this power belongs to the President.

The SC also ruled that the President did not commit grave abuse of discretion when he certified as urgent House Bill No. 8980, now the 2024 GAA, which dispensed with the requirement of reading on three separate days and the printing and distribution of copies in advance.

The SC also denied the petitioners’ request to determine the liability of the DOF Secretary for technical malversation and/or plunder, ruling that such matters are improper for resolution in this case. The only issue properly before it is the validity of the issuances and whether they were issued with grave abuse of discretion amounting to a lack or excess of jurisdiction. The Justices who submitted their respective separate opinions also noted that no criminal liability can attach to the Finance Secretary, who they found to have acted in good faith in implementing Special Provision 1(d).

The SC ordered that the remitted funds amounting to PHP 60 billion be returned to PhilHealth through the 2026 GAA.

Separate Opinions

Senior Associate Justice Marvic M.V.F. Leonen held that the presidential declaration of urgency should be considered invalid, noting that no emergency or public calamity justified dispensing with the constitutional requirement of three readings on separate days.

Associate Justice Alfredo Benjamin S. Caguioa emphasized that Congress exceeded its authority when it increased the unprogrammed appropriations proposed by the President, describing the move as a deliberate attempt to circumvent the constitutional prohibition against increasing the President’s proposed appropriations.

Associate Justice Ramon Paul L. Hernando held that unprogrammed appropriations in the GAA are unconstitutional and that the entire amount should be removed.

Associate Justice Henri Jean Paul B. Inting stated that the President’s certification of the bill as urgent was based on a reasonable assessment of the country’s needs and not an act of grave abuse of discretion.

Associate Justice Rodil V. Zalameda expressed reservation on the wholesale invalidation of Special Provision No. 1 (d) and DOF Circular No. 003-2024, saying that while he agreed that the transfer was unconstitutional, he held that the government may nonetheless be considered to have acted in good faith.

Associate Justice Samuel H. Gaerlan held that declaring the issuances invalid does not negate the good faith of the Finance Secretary in implementing Special Provision No. 1 (d) through DOF Circular No. 003-2024, nor does it automatically create a basis for his liability.

Associate Justice Ricardo R. Rosario emphasized that a finding of grave abuse of discretion by a public official does not equate to criminal liability.

Associate Justice Jhosep Y. Lopez disagreed with striking down Special Provision No. 1 (d) and DOF Circular No. 003-2024 in their entirety, asserting that the ruling should be limited solely to the transfer of PhilHealth funds.

Associate Justice Japar B. Dimaampao held that the wholesale invalidation of Special Provision No. 1 (d) and DOF Circular No. 003-2024 should be avoided as these can be reconciled with the UHCA and the Sin Tax Laws.

Associate Justice Jose Midas P. Marquez likewise disagreed with the broad invalidation of the issuances. He held that Special Provision No. 1 (d) enjoys the presumption of constitutionality and should be harmonized with the Constitution.

Associate Justice Maria Filomena D. Singh noted that the transfer diverted funds intended for indigents, senior citizens, and persons with disabilities, weakening PhilHealth’s capacity to provide universal healthcare and marginalized Filipinos of essential support.

Associate Justice Raul B. Villanueva disagreed with declaring Special Provision No. 1 (d) unconstitutional, arguing that it did not directly repeal the UHCA and Sin Tax Laws. He added that Special Provision No. 1 (d) should be applied to GOCCs whose charters do not prohibit such transfer of funds.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=156834

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=156755

Read the Separate Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=156760

Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/?p=156766

Read the Separate Concurring and Dissenting Opinion of Associate Justice Ramon Paul L. Hernando at https://sc.judiciary.gov.ph/?p=156771

Read the Separate Concurring Opinion of Associate Justice Henri Jean Paul B. Inting at https://sc.judiciary.gov.ph/?p=156776

Read the Separate Concurring Opinion of Associate Justice Rodil V. Zalameda at https://sc.judiciary.gov.ph/?p=156781

Read the Separate Concurring Opinion of Associate Justice Samuel H. Gaerlan at https://sc.judiciary.gov.ph/?p=156786

Read the Concurring Opinion of Associate Justice Ricardo R. Rosario at https://sc.judiciary.gov.ph/?p=156792

Read the Separate Concurring Opinion of Associate Justice Jhosep Y. Lopez at https://sc.judiciary.gov.ph/?p=156797

Read the Separate Opinion of Associate Justice Japar B. Dimaampao at https://sc.judiciary.gov.ph/?p=156802

Read the Separate Opinion of Associate Justice Jose Midas P. Marquez at https://sc.judiciary.gov.ph/?p=156807

Read the Separate Concurring Opinion of Associate Justice Maria Filomena D. Singh at https://sc.judiciary.gov.ph/?p=156812

Read the Separate Opinion of Associate Justice Raul B. Villanueva at https://sc.judiciary.gov.ph/?p=156820

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

30/12/2025

The (SC) has held that while financial details of bank deposits remain confidential, the Cybercrime Prevention Act allows disclosure of bank account holder information for cybercrime investigations.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division denied the petition filed by EastWest Rural Bank (EastWest), which questioned the warrant to disclose computer data (WDCD) issued by the court and the subsequent Disclosure Order issued by the Philippine National Police Anti-Cybercrime Group (PNP-ACG) which required EastWest to disclose bank account holder information.

This EastWest bank account holder information sought to be disclosed is the account where Leonard Vendiola’s money was transferred after he was scammed by a caller posing as a bank employee.

Vendiola reported to the PNP-ACG that a caller who introduced herself as a bank employee deceived him by promising rewards contingent to disclosing his email and one-time password. When he checked his bank account, he discovered that an amount of PHP 10,000 was transferred to an EastWest account.

PNP-ACG applied for a WDCD to identify the EastWest account holder involved in the alleged scam. This was granted by the Regional Trial Court which authorized the PNP-ACG to compel EastWest to disclose and preserve data relating to the account holder. Pursuant to this, the PNP-ACG issued a Disclosure Order to EastWest.

EastWest filed a petition with the Court of Appeals challenging the WDCD and arguing that the Bank Secrecy Law prohibits banks from revealing any information about bank deposits, including the identity of the account holder. It maintained that this rule remains in force because it was not repealed by the Cybercrime Prevention Act.

EastWest also asserted that it should not be subject to the Cybercrime law’s disclosure rules because it is a financial institution rather than a communications service provider.

The SC rejected these arguments and upheld the validity of the WDCD and Disclosure Order.

The SC clarified that while the Bank Secrecy Law protects the confidentiality of bank deposits and their financial details, it does not prevent the disclosure of basic identifying information when allowed by law. Under the Cybercrime Prevention Act, law enforcement agencies may, with a court-issued warrant, require the disclosure of computer data necessary to investigate cybercrime offenses.

The SC ruled that EastWest is considered a service provider under the Cybercrime Prevention Act because their digital banking services, such as online banking platforms, mobile applications, and automated email notifications, allow customers to communicate and transact through computer systems. As a banking institution, EastWest also processes and stores substantial amounts of computer data both in the course of its operations and on behalf of its customers, placing it within the law’s coverage for the disclosure of computer data when authorized by a court-issued warrant.

Read the full text of the press release at http://sc.judiciary.gov.ph/?p=157653

Read the full text of the Decision at http://sc.judiciary.gov.ph/?p=157646

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

30/12/2025

The has laid down guideposts for proving who owns or controls a social media account in criminal cases.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed the conviction of an individual (###) for committing psychological violence under Section 5 (i) of the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 (𝘈𝘯𝘵𝘪-𝘝𝘈𝘞𝘊) 𝘈𝘤𝘵 against his ex-girlfriend (AAA) by posting derogatory statements about her on 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬.

The SC sentenced ### to up to eight years in prison, imposed a PHP 100,000 fine, and ordered ### to undergo psychological counseling or psychiatric treatment.

The SC stressed that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender.

It explained that for crimes committed through social media, the basic features of the platform such as 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬, must be considered.

Noting that 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 is widely used in the Philippines, the SC held that a 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 account can easily be created by anyone claiming to be at least 13 years old with an email address or mobile number.

Once an account is created, the user can add friends, exchange private messages, and post statements, photos, or videos visible to others depending on the user’s privacy settings. Fake or dummy accounts can easily spread, enabling disinformation, identity theft, or crimes.

Given this, the SC ruled that guideposts are necessary to establish who owns or controls a social media account. It said the following must be shown to prove ownership or access:

1. Admission of ownership or authorship;
2. Being seen accessing the account or composing the post;
3. Containing information known only to the offender or a few people;
4. Language consistent with the offender’s characteristics;
5. Records from the internet service provider, telecommunications company, or social media site, and results from device forensic analysis showing geolocation features, and other attributes linking the account to the offender;
6. Acts consistent with previous posts; or
7. Other instances showing ownership, access, or authorship.

Applying these, the SC found that several factors proved ### wrote the 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 post. The account name bore his full name, and the profile photo showed him with his child from his current live-in partner.

AAA’s sister had also received messages from the same account for years.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=158535.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=158446.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

18/12/2025

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