Veterans Federation Party v. COMELEC[G.R. No. 136781.October 6, 2000]FACTS:COMELEC proclaimed 14 party-list representatives from 13 parties, which obtained at least 2% of the total number of votes cast for the party-list system as members of the House of Representatives. Upon petition for respondents, who were party-list organizations, it proclaimed 38 additional party-list representatives although they obtained less than 2% of the total number of votes cast for the party-list system on the ground that under the Constitution, it is mandatory that at least 20% of the members of the House of Representatives come from the party-list representatives.

ISSUE:Is the twenty percent allocation for party-list representatives mentioned in Section 5 (2), Article VI of the Constitution, mandatory or is it merely a ceiling? In other words, should the twenty percent allocation for party-list solons be filled up completely and all the time?

HELD:It is not mandatory. It merely provides a ceiling for the party-list seats in the House of Representatives. The Constitution vested Congress with the broad power to define and prescribe the mechanics of the party-list system of representatives. In the exercise of its constitutional prerogative, Congress deemed it necessary to require parties participating in the system to obtain at least 2% of the total votes cast for the party list system to be entitled to a party-list seat. Congress wanted to ensure that only those parties having a sufficient number of constituents deserving of representation are actually represented in Congress.

FORMULAS

determination of total number of party-list representatives=#ofdistrictrepresentatives/.80x.20

additional representatives of first party=#ofvotesoffirstparty/#ofvotesofpartylistsystem

additional seats for concerned party=# of votes of concerned party/ # votes of first party x additional seats for concerned party

ISSUE:Whether or not the two percent threshold requirement and the three-seat limit provided in Section 11 (b) of RA 7941 are constitutional.

HELD:Yes. In imposing a two percent threshold, Congress wanted to ensure that only those parties, organizations and coalitions having a sufficient number of constituents deserving of representation are actually represented in Congress. This intent can be gleaned from the deliberations on the proposed bill. The two percent threshold is consistent not only with the intent of the framers of the Constitution and the law, but with the very essence of "representation." Under a republican or representative state, all government authority emanates from the people, but is exercised by representatives chosen by them. But to have meaningful representation, the elected persons must have the mandate of a sufficient number of people. Otherwise, in a legislature that features the party-list system, the result might be the proliferation of small groups which are incapable of contributing significant legislation, and which might even pose a threat to the stability of Congress. Thus, even legislative districts are apportioned according to "the number of their respective inhabitants, and on the basis of a uniform and progressive ratio" to ensure meaningful local representation.

ISSUE:How should the additional seats of a qualified party be determined?

HELD:Step One. There is no dispute among the petitioners, the public and the private respondents, as well as the members of this Court that the initial step is to rank all the participating parties, organizations and coalitions from the highest to the lowest based on the number of votes they each received. Then the ratio for each party is computed by dividing its votes by the total votes cast for all the parties participating in the system. All parties with at least two percent of the total votes are guaranteed one seat each. Only these parties shall be considered in the computation of additional seats. The party receiving the highest number of votes shall thenceforth be referred to as the first party.Step Two. The next step is to determine the number of seats the first party is entitled to, in order to be able to compute that for the other parties. Since the distribution is based on proportional representation, the number of seats to be allotted to the other parties cannot possibly exceed that to which the first party is entitled by virtue of its obtaining the most number of votes.Step three. The next step is to solve for the number of additional seats that the other qualified parties are entitled to, based on proportional representation.

BAYAN MUNAvs.COMELECG.R. No. 147613 June 26, 2001

FACTS:Petitioners challenged the Comelecs Omnibus Resolution No. 3785,which approved the participation of 154 organizations and parties, including those herein impleaded, in the 2001 party-list elections. Petitioners sought the disqualification of private respondents, arguing mainly that the party-list system was intended to benefit the marginalized and underrepresented; not the mainstream political parties, the non-marginalized or overrepresented.Unsatisfied with the pace by which Comelec acted on their petition, petitioners elevated the issue to the Supreme Court.

ISSUE:1.Whether or not petitioners recourse to the Court was proper.2.Whether or not political parties may participate in the party list elections.3.Whether or not the Comelec committed grave abuse of discretion in promulgating Omnibus Resolution No. 3785.

RULING:1.The Court may take cognizance of an issue notwithstanding the availability of other remedies "where the issue raised is one purely of law, where public interest is involved, and in case of urgency." The facts attendant to the case rendered it justiciable.

2.Political parties even the major ones -- may participate in the party-list elections subject to the requirements laid down in the Constitution and RA 7941, which is the statutory law pertinent to the Party List System.

Under the Constitution and RA 7941, private respondents cannot be disqualified from the party-list elections, merely on the ground that they are political parties. Section 5, Article VI of the Constitution provides that members of the House of Representatives may "be elected through a party-list system of registered national, regional, and sectoral parties or organizations. It is however, incumbent upon the Comelec to determine proportional representation of the marginalized and underrepresented, the criteria for participation, in relationto the cause of the party list applicants so as to avoid desecration of the noble purpose of the party-list system.

3.The Court acknowledged that to determine the propriety of the inclusion of respondents in the Omnibus Resolution No. 3785, a study of the factual allegations was necessary which was beyond the pale of the Court. The Court not being a trier of facts.

However, seeing that the Comelec failed to appreciate fully the clear policy of the law and the Constitution, the Court decided to set some guidelines culled from the law and the Constitution, to assist the Comelec in its work. The Court ordered that the petition be remanded in the Comelec to determine compliance by the party lists.

ATONG PAGLAUM VSCOMELEC[G.R. NO. 203766 ETC., 02 APRIL 2013]

FACTS:A few weeks before the elections, the Supreme Court in Atong Paglaum Inc. vs. Commission on Elections reinterpreted Section 5, Article VI of the Constitution and reversed its own ruling in Ang Bagong Bayani and Barangay Association forNational Advancement and Transparency v. Commission onElections (BANAT).

In granting the petition of 52 party list groupsand organizations which were disqualified by the Commission on Election from participating in the May 13, 2013 party list elections because they allegedly do not represent the marginalized and underrepresented sector of society, the majority is of the view that the party list system includes not only sectoral parties butalso non-sectoral parties. Hence, contrary to the Ang Bagong Bayani, the party-list system is not the exclusive domain of sectoral representatives belonging to the marginalized and underrepresented sectors but may be participated by non-sectoral parties as well as who do not need to represent the marginalized and underrepresented sector.

ISSUE:Whether or not Comelec committed grave abuse of discretion in following prevailing decisions of this court in disqualifying petitioners from participating in the coming 13may 2013 party-list elections.HELD:We hold that the Comelec did not commit grave abuse of discretion in following prevailing decisions of this court in disqualifying petitioners from participating in the coming 13may 2013 party-list elections. However, since the court adopts in thisdecision new parameters in thequalification of national, regional, and sectorial parties under the party-list system, thereby abandoning the rulings in the decisions applied by the Comelec in disqualifying petitioners, we remand to allthe present petitions for the Comelec todetermine who are qualified to register under the party-list system, and to participate in the coming 13 may 2013 party-list elections, under the new parameters prescribed in thisdecision.What is the objective of the party list system under the 1987 constitution?Todemocratize political powerby giving political parties that cannot win in legislative district elections a chance to win seats in the house ofrepresentatives.Who are included in the party list system?(1)Sectoral parties(2)Non-sectoral parties.What is the proof that the party list system isnot exclusively for sectoral parties?Section 5(2), Article VI of the1987 Constitution

NOTES: Political parties can participate in the party-list system [f]or as long as they filed candidates who come from the different marginalized sectors that we shall designate in thisconstitution. Three different groups: (1) national parties or organizations; (2) regional parties or organizations; and (3) sectoralpartiesororganizations. Mandates that, during the first three consecutive terms of congress after the ratification of the 1987 constitution, one-half of the seatsallocated to party-list representatives shall be filled, as provided by law, by selection or election from the labor, peasant, urban poor,indigenous cultural communities, women, youth, and such other sectors as may be provided bylaw, except the religious sector.

ANG LADLAD LGBT PARTY vs. COMMISSION ON ELECTIONSG.R. No. 190582 April 8, 2010FACTS:Comelec refused to recognize Ang Ladlad LGBT Party,an organization composed of men and women who identify themselves as lesbians, gays, bisexuals, or trans-gendered individuals (LGBTs), as a party list based on moral grounds. In the elevation of the case to the Supreme Court, Comelec alleged that petitioner made misrepresentation in their application.

ISSUE:Whether or not Ang Ladlad LGBT Party qualifies for registration as party-list.

HELD:Ang Ladlad LGBT Partys application for registration should be granted.

Comelecs citation of the Bible and the Koran in denying petitioners application was a violation of the non-establishment clause laid down in Article 3 section 5 of the Constitution. The proscription by law relative to acts against morality must be for a secular purpose (that is, the conduct prohibited or sought to be repressed is detrimental or dangerous to those conditions upon which depend the existence and progress of human society"),rather than out of religious conformity. The Comelec failed to substantiate their allegation that allowing registration to Ladlad would be detrimental to society.

The LGBT community is not exempted from the exercise of its constitutionally vested rights on the basis of their sexual orientation. Laws of general application should apply with equal force to LGBTs, and they deserve to participate in the party-list system on the same basis as other marginalized and under-represented sectors. Discrimination based on sexual orientation is not tolerated ---not by our own laws nor by any international laws to which we adhere.

Senate v. ErmitaG.R. No. 169777 *April 20, 2006

FACTS:This is a petition for certiorari and prohibition proffer that the President has abused power by issuing E.O. 464 Ensuring Observance of the Principles of Separation of Powers, Adherence to the Rule on Executive Privilege and Respect for the Rights of Public Officials Appearing in Legislative Inquiries inAid of Legislation Under the Constitution, and for Other Purposes. Petitioners pray for its declaration as null and void for being unconstitutional.In the exercise of its legislative power, the Senate of the Philippines, through its various Senate Committees, conducts inquiries or investigations in aid of legislation which call for, inter alia, the attendance of officials and employees of the executive department, bureaus, and offices including those employed in Government Owned and Controlled Corporations, the Armed Forces of the Philippines (AFP), and the Philippine National Police (PNP).

The Committee of the Senate issued invitations to various officials of the Executive Department for them to appear as resource speakers in a public hearing on the railway project, others on the issues of massive election fraud in the Philippine elections, wire tapping, and the role of military in the so-called Gloriagate Scandal.

Said officials were not able to attend due to lack of consent from the President as provided by E.O. 464, Section 3 which requires all the public officials enumerated in Section 2(b) to secure the consent of the President prior to appearing before either house of Congress.

ISSUE:

Is Section 3 of E.O. 464, which requires all the public officials, enumerated in Section 2(b) to secure the consent of the President prior to appearing before either house of Congress, valid and constitutional?

RULING:

No. The enumeration in Section 2 (b) of E.O. 464 is broad and is covered by the executive privilege. The doctrine of executive privilege is premised on the fact that certain information must, as a matter of necessity, be kept confidential in pursuit of the public interest. The privilege being, by definition, an exemption from the obligation to disclose information, in this case to Congress, the necessity must be of such high degree as to outweigh the public interest in enforcing that obligation in a particular case.

Congress undoubtedly has a right to information from the executive branch whenever it is sought in aid of legislation. If the executive branch withholds such information on the ground that it is privileged, it must so assert it and state the reason therefor and why it must be respected.

The infirm provisions of E.O. 464, however, allow the executive branch to evade congressional requests for information without need of clearly asserting a right to do so and/or proffering its reasons therefor. By the mere expedient of invoking said provisions, the power of Congress to conduct inquiries in aid of legislation is frustrated.--------------------------------------

FACTS:In 2005,scandalsinvolving anomalous transactions about the North Rail Project as well as the Garci tapes surfaced. This prompted the Senate to conduct a public hearing to investigate the said anomalies particularly the alleged overpricing in the NRP. The investigating Senate committee issued invitations to certain department heads and military officials to speak before the committee as resource persons. Ermita submitted that he and some of the department heads cannot attend the said hearing due to pressing matters that needimmediateattention. AFP Chief of Staff Senga likewise sent asimilarletter.

Drilon, the senate president, accepted the said requests for they were sent belatedly and arrangements were already made and scheduled. Subsequently, GMA issued EO 464, which took effect immediately. EO 464basically prohibited Department heads, Senior officials of executive departments who in the judgment of the department heads are covered by the executive privilege; Generals and flag officers of the Armed Forces of the Philippines and such other officers who in the judgment of the Chief of Staff are covered by the executive privilege; Philippine National Police (PNP) officers with rank of chief superintendent or higher and such other officers who in the judgment of the Chief of the PNP are covered by the executive privilege; Senior national security officials who in the judgment of the National Security Adviser are covered by the executive privilege; and Such other officers as may be determined by the President, from appearing in such hearings conducted by Congress without first securing the presidents approval. The department heads and the military officers who were invited by the Senate committee then invoked EO 464 to except themselves. Despite EO 464, the scheduled hearing proceeded with only 2 military personnel attending. For defying President Arroyos order barring military personnel from testifying before legislative inquiries without her approval, Brig. Gen. Gudani and Col. Balutan were relieved from their military posts and were made to face court martial proceedings. EO 464s constitutionality was assailed for it is alleged that it infringes on the rights and duties of Congress to conduct investigation in aid of legislation and conduct oversight functions in the implementation of laws.

ISSUE:Whether or not EO 464 is constitutional.

HELD:The SC ruled that EO 464 is constitutional in part. To determine the validity of the provisions of EO 464, the SC sought to distinguish Section 21 from Section 22 of Art 6 of the 1987 Constitution. The Congress power of inquiry is expressly recognized in Section 21 of Article VI of the Constitution. Although there is no provision in the Constitution expressly investing either House of Congress with power to make investigations and exact testimony to the end that it may exercise its legislative functions advisedly and effectively, such power is so far incidental to the legislative function as to be implied. In other words, the power of inquiry with process to enforce it is an essential and appropriate auxiliary to the legislative function. A legislative body cannot legislate wisely or effectively in the absence of information respecting the conditions which the legislation is intended to affect or change; and where the legislative body does not itself possess the requisite information which is not infrequently true recourse must be had to others who do possess it. Section 22 on the other hand provides for the Question Hour. The Question Hour is closely related with the legislative power, and it is precisely as a complement to or a supplement of the Legislative Inquiry. The appearance of the members of Cabinet would be very, very essential not only in the application of check and balance but also, in effect, in aid of legislation. Section 22 refers only to Question Hour, whereas, Section 21 would refer specifically to inquiries in aid of legislation, under which anybody for that matter, may be summoned and if he refuses, he can be held in contempt of the House. A distinction was thus made between inquiries in aid of legislation and the question hour. While attendance was meant to be discretionary in the question hour, it was compulsory in inquiries in aid of legislation. Sections 21 and 22, therefore, while closely related and complementary to each other, should not be considered as pertaining to the same power of Congress. One specifically relates to the power to conduct inquiries in aid of legislation, the aim of which is to elicit information that may be used for legislation, while the other pertains to the power to conduct a question hour, the objective of which is to obtain information in pursuit of Congress oversight function. Ultimately, the power of Congress to compel the appearance of executive officials under Section 21 and the lack of it under Section 22 find their basis in the principle of separation of powers. While the executive branch is a co-equal branch of the legislature, it cannot frustrate the power of Congress to legislate by refusing to comply with its demands for information. When Congress exercises its power of inquiry, the only way for department heads to exempt themselves therefrom is by a valid claim of privilege. They are not exempt by the mere fact that they are department heads. Only one executive official may be exempted from this power the President on whom executive power is vested, hence, beyond the reach of Congress except through the power of impeachment. It is based on her being the highest official of the executive branch, and the due respect accorded to a co-equal branch of government which is sanctioned by a long-standing custom. The requirement then to secure presidential consent under Section 1, limited as it is only to appearances in the question hour, is valid on its face. For under Section 22, Article VI of the Constitution, the appearance of department heads in the question hour is discretionary on their part. Section 1 cannot, however, be applied to appearances of department heads in inquiries in aid of legislation. Congress is not bound in such instances to respect the refusal of the department head to appear in such inquiry, unless a valid claim of privilege is subsequently made, either by the President herself or by the Executive Secretary.

When Congress merely seeks to be informed on how department heads are implementing the statutes, which it has issued, its right to such information is not as imperative as that of the President to whom, as Chief Executive, such department heads must give a report of their performance as a matter of duty. In such instances, Section 22, in keeping with the separation of powers, states that Congress may only request their appearance. Nonetheless, when the inquiry in which Congress requires their appearance is in aid of legislation under Section 21, the appearance is mandatory for the same reasons stated in Arnault.

203 SCRA 767 Political Law Constitutional Law The Legislative Department Inquiry in Aid of Legislation When not AllowedPENGSON vs BLUE RIBBON COMMITTEEFACTS:It was alleged that Benjamin Kokoy Romualdez and his wife together with the Marcoses unlawfully and unjustly enriched themselves at the expense of the Filipino people. That they obtained with the help of the Bengzon Law Office and Ricardo Lopa Corys brother in law, among others, control over some of the biggest business enterprises in the country including MERALCO, PCI Bank, Shell Philippines and Benguet Consolidated Mining Corporation.Senator Juan Ponce Enrile subsequently delivered a privilege speech alleging that Lopa took over various government owned corporations, which is in violation of the Anti-Graft and Corrupt Practices Act. Contained in the speech is a motion to investigate on the matter. The motion was referred to the Committee on Accountability of Public Officers or the Blue Ribbon Committee. After committee hearing, Lopa refused to testify before the committee for it may unduly prejudice a pending civil case against him. Bengzon likewise refused invoking his right to due process. Lopa however sent a letter to Enrile categorically denying his allegations and that his allegations are baseless and malicious.Enrile subsequently took advantage of the Senates privilege hour upon which he insisted to have an inquiry regarding the matter. The SBRC rejected Lopas and Bengzons plea.Claiming that the Senate Blue Ribbon Committee is poised to subpoena them and require their attendance and testimony in proceedings before the Committee, in excess of its jurisdiction and legislative purpose, in clear and blatant disregard of their constitutional rights, and to their grave and irreparable damage, prejudice and injury, and that there is no appeal nor any other plain, speedy and adequate remedy in the ordinary course of law, Bengzon et al filed apetition for prohibition with a prayer for temporary restraining order and/or injunctive relief against the SBRC.ISSUE:Whether or not the inquiry sought by the SBRC should be granted.HELD:No, the inquiry cannot be given due course. The speech of Enrile contained no suggestion of contemplated legislation; he merely called upon the Senate to look into a possible violation of Sec. 5 of RA No. 3019, otherwise known as The Anti-Graft and Corrupt Practices Act. In other words, the purpose of the inquiry to be conducted by the Blue Ribbon Committee was to find out whether or not the relatives of Cory, particularly Lopa, had violated the law in connection with the alleged sale of the 36 or 39 corporations belonging to Kokoy to the Lopa Group. There appears to be, therefore, no intended legislation involved. Hence, the contemplated inquiry by the SBRC is not really in aid of legislation because it is not related to a purpose within the jurisdiction of Congress, since the aim of the investigation is to find out whether or not the relatives of the President or Mr. Ricardo Lopa had violated Section 5 of RA No. 3019, the Anti-Graft and Corrupt Practices Act, a matter that appears more within the province of the courts rather than of the legislature. Besides, the Court may take judicial notice that Mr. Ricardo Lopa died during the pendency of this case.

235 SCRA 630 (1994) 249 SCRA 635 (1995) Political Law Origination of Revenue Bills EVAT Amendment by SubstitutionTOLENTINO vs SECRETARY OF FINANCE235 SCRA 630Arturo Tolentino et al are questioning the constitutionality of RA 7716 otherwise known as the Expanded Value Added Tax (EVAT) Law. Tolentino averred that this revenue bill did not exclusively originate from the House of Representatives as required by Section 24, Article 6 of the Constitution. Even though RA 7716 originated as HB 11197 and that itpassed the3 readings in the HoR, the same did not complete the 3 readings in Senate for after the 1streading it was referred to the Senate Ways & Means Committee thereafter Senate passed its own version known as Senate Bill 1630. Tolentino averred that what Senate could have done is amend HB 11197 by striking out its text and substituting it with the text of SB 1630 in that way the bill remains a House Bill and the Senate version just becomes the text (only the text) of the HB. (Its ironichowever to note that Tolentino and co-petitioner Raul Roco even signed the said Senate Bill.)ISSUE:Whether or notthe EVAT law is procedurally infirm.HELD:No.By a 9-6 vote, the Supreme Court rejected the challenge, holding that such consolidation was consistent with the power of the Senate to propose or concur with amendments to the version originated in the HoR. What the Constitution simply means, according to the 9 justices, is that the initiative must come from the HoR. Note also that there were several instances before where Senate passed its own version rather than having the HoR version as far as revenue and other such bills are concerned. This practice of amendment by substitution has always been accepted. The proposition of Tolentino concerns a mere matter of form. There is no showing that it would make a significant difference if Senate were to adopt his over what has been done.Political Law Election Laws Absentee Voters Act Proclamation of Winners in a National Elections

MACALINTAL vs COMELEC Romulo Macalintal, as alawyerand ataxpayer, questions the validity of the Overseas Absentee Voting Act of 2003 (R.A. 9189). He questions the validity of the said act on the following grounds, among others:(1) That the provision that a Filipino already considered an immigrant abroad can be allowed to participate in absentee voting provided he executes an affidavit stating his intent to return to the Philippines is void because it dispenses of the requirement that a voter must be a resident of the Philippines for at least one year and in the place where he intends to vote for at least 6 months immediately preceding the election;(2) That the provision allowing the Commission on Elections (COMELEC) to proclaim winning candidates insofar as it affects the canvass of votes and proclamation of winning candidates for president and vice-president, is unconstitutional because it violates the Constitution for it is Congress which is empowered to do so.ISSUE:Whether or not Macalintals arguments are correct.HELD:No.(1) There can be no absentee voting if the absentee voters are required to physically reside in the Philippines within the period required for non-absentee voters. Further, as understood in election laws, domicile and resident are interchangeably used. Hence, one is a resident of his domicile (insofar as election laws is concerned). The domicile is the place where one has the intention to return to. Thus, an immigrant who executes an affidavit stating his intent to return to the Philippines is considered a resident of the Philippines for purposes of being qualified as a voter (absentee voter to be exact). If the immigrant does not execute the affidavit then he is not qualified as an absentee voter.(2) The said provision should be harmonized. It could not be the intention of Congress to allow COMELEC to include the proclamation of the winners in the vice-presidential and presidential race. To interpret it that way would mean that Congress allowed COMELEC to usurp its power. The canvassing and proclamation of the presidential and vice presidential elections is still lodged in Congress and was in no way transferred to the COMELEC by virtue of RA 9189.*READ THE DISSENTING OPINION OF JUSTICE PUNO

ABAKADA GURO vs. PURISIMA

FACTS:Republic Act No. 9335 was enacted to optimize the revenue-generation capability and collection of the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). It provides a system of rewards and sanctions through the creation of Rewards and Incentives Fund (Fund) and a Revenue Performance Evaluation Board (Board) to BIR and BOC officials and employees if they exceed their revenue targets.It covers all officials and employees of the BIR and the BOC with at least six months of service, regardless of employment status.

Petitioners, invoking their right as taxpayers, filed this petition challenging the constitutionality of RA 9335, a tax reform legislation. They contend that the limiting the scope of the system of rewards and incentives only to officials and employees of the BIR and the BOC violates the constitutional guarantee of equal protection. There is no valid basis for classification or distinction as to why such a system should not apply to officials and employees of all other government agencies.

Respondent contends that the allegation that the reward system will breed mercenaries is mere speculation and does not suffice to invalidate the law. Seen in conjunction with the declared objective of RA 9335, the law validly classifies the BIR and the BOC because the functions they perform are distinct from those of the other government agencies and instrumentalities.

ISSUE:

Whether or Not there is a violation of equal protection clause.

HELD:

Equality protection is equality among equals, not similarity of treatment of persons who are classified based on substantial differences in relation to the object to be accomplished.When things or persons are different in fact or circumstance, they may be treated in law differently.

The Constitution does not require that things, which are different in fact, be treated in law as though they were the same. The equal protection clause does not forbid discrimination as to things that are different.It does not prohibit legislation, which is limited either in the object to which it is directed.

The equal protection clause recognizes a valid classification, that is, a classification that has a reasonable foundation or rational basis and not arbitrary.22With respect to RA 9335, its expressed public policy is the optimization of the revenue-generation capability and collection of the BIR and the BOC.23Since the subject of the law is the revenue- generation capability and collection of the BIR and the BOC, the incentives and/or sanctions provided in the law should logically pertain to the said agencies. Moreover, the law concerns only the BIR and the BOC because they have the common distinct primary function of generating revenues for the national government through the collection of taxes, customs duties, fees and charges.

Both the BIR and the BOC are bureaus under the DOF. They principally perform the special function of being the instrumentalities through which the State exercises one of its great inherent functions taxation. Indubitably, such substantial distinction is germane and intimately related to the purpose of the law. Hence, the classification and treatment accorded to the BIR and the BOC under RA 9335 fully satisfy the demands of equal protectio