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ISSUE: W/N DBM’s policy of “No Report, No Release” is constitutional
FACTS: CSC filed a petition for mandamus seeking to compel the DBM to release the balance of its budget for fiscal year 2002. At the same time, it seeks a determination by this Court of the extent of the constitutional concept of fiscal autonomy. General Appropriation Act of 2002 (GAA) appropriated total funds to the CSC but they claimed that there is an unreleased balance. To CSC, this balance was intentionally withheld by DBM on the basis of its no report, no release policy. DBM proffers at any rate that the delay in releasing the balance of CSC budget was not on account of any failure on CSC part to submit the required reports; rather, it was due to a shortfall in revenues. Moreover, DBM contends that CSC did not exhaust administrative remedies as it could have sought clarification from DBM Secretary regarding the extent of fiscal autonomy before resorting to Court. Second, even assuming that administrative remedies were exhausted, there are no exceptional and compelling reasons to justify the direct filing of the petition with Supreme Court instead of the trial court, thus violating the hierarchy of courts.
RATIO DECIDENDI: DBM’s policy of “No Report, No Release” may not be validly enforced against offices possessing fiscal autonomy without violating Article IX (A), Section 5 of the Constitution which states: The Commission shall enjoy fiscal autonomy. Their approved annual appropriations shall be automatically and regularly released. It is under such situation that a relaxation of the constitutional mandate to automatically and regularly release appropriations is allowed. Their approved appropriations shall be automatically and regularly released.