The memorandum circulars provide, among others, for the full disclosure of the LGUs’ budgets.
Former Camarines Sur Governor Luis Raymond Villafuerte Jr. had questioned the legality of Memorandum Circular 2010-83, Memorandum Circular (MC) 2010-138 and Memorandum Circular 2011-08 for “lack of merit.”
MC 2010-83 pertains to the full disclosure of local budgets and finances and bids and public offering.
MC 2010-138, on the other hand, pertains to the use of the 20 percent component of the annual Internal Revenue Allotment (IRA) shares.
MC 2011-08, meanwhile, pertains to the strict adherence by local government units on Section 90 of Republic Act 10147 or the General Appropriations Act of 2011.
Villafuerte claimed Robredo, who died in 2012 in a plane crash, went beyond his supervisory powers. He said the circulars violate local and fiscal autonomy.
The SC dismissed his claims, saying “it is inconceivable, however, how the publication of budgets, expenditures, contracts and loans and procurement plans of local government units required in the assailed issuances could have infringed on the local fiscal autonomy of local government units.”
“The posting requirements are mere transparency measures which do not at all hurt the manner by which local government units decide the utilization and allocation of their funds,” it added.