Case Digest: Philconsa vs. Mathay

ISSUE:  Whether or not the salary increase was constitutional? 

FACTS:  RA 4134 provided for increase of salary of Senate President, Speaker of the House and members of the Senate and House of Representatives. This took effect on 30 June 1966. However record show that the increase was implemented on 1964.Philippine Constitution Association assailed the validity of RA 4134, stating that this is in violation of Section 14 Article 6 of the Constitution, “No increase in said compensation shall take effect until after the expiration of the full term of all the members of the Senate and House of Representatives approving such increase. Thus the petition for writ of prohibition. 

RATIO DECIDENDI:  Republic Act No. 4134 is not operative until December 30, 1969, when the full term of all members of the Senate and House that approved it on June 20, 1964 will have expired. Consequently, appropriation for such increased compensation may not be disbursed until December 30, 1969. In so far as Republic Act No. 4642 (1965-1966 Appropriation Act) authorizes the disbursement of the increased compensation prior to the date aforesaid, it also violates the Constitution and must be held null and void.