Budget Battles: PMA and PNPA’s Inclusion in Education Sparks Constitutional Showdown

By Louis ‘Barok‘ C. Biraogo — January 8, 2025

WHEN does funding education become a constitutional gray area? By including the Philippine Military Academy (PMA) and Philippine National Police Academy (PNPA) under the education sector in the 2025 budget, the Philippine government may have crossed that line. Supporters applaud this as pragmatic leadership, while critics see a calculated move to skirt the Constitution’s priorities.

The Government’s Perspective: Understanding the Rationale Behind the Decision

Executive Secretary Lucas Bersamin emphasized the need for a “broader understanding” of the Constitution, asserting that education responsibilities extend beyond the Department of Education (DepEd) to include other agencies like the Commission on Higher Education (CHED), Technical Education and Skills Development Authority (TESDA), and state educational institutions, such as the PMA and PNPA. He contended that including these academies in the education sector aligns with the Constitution’s directive to prioritize education, albeit interpreted more expansively.

The Constitution and Education: A Closer Look at the Relevant Provision to the PMA/PNPA Funding Decision

The 1987 Constitution mandates that education receive the highest budgetary priority (Article XIV, Section 5(5)). Historically, this has been understood to mean prioritizing DepEd, CHED, TESDA, and state universities and colleges. Critics argue that this decision dilutes the intended focus on foundational and accessible education for the general public.

The Case for Inclusion: Examining the Arguments in Favor of Including PMA and PNPA in the Education Sector

  1. Holistic Interpretation of Education: The Constitution does not narrowly define “education.” By this broader interpretation, the training provided by the PMA and PNPA can be viewed as an essential component of education contributing to national development.
  2. Budget Optimization: Consolidating PMA and PNPA funding under the education budget could streamline resource allocation and enhance budgetary efficiency.
  3. Public Service Preparation: Including PMA and PNPA underscores their role in training individuals for vital national security and law enforcement roles, which have educational components.

Challenging the Decision: Analyzing the Arguments Against Including PMA and PNPA in the Education Sector

  1. Constitutional Deviation: Critics argue that the framers of the Constitution intended the education budget to focus on traditional academic institutions accessible to the general population.
  2. Budgetary Misrepresentation: Including PMA and PNPA funds under education might artificially inflate the sector’s budget, undermining transparency and trust.
  3. Erosion of Prioritization: This reclassification could set a dangerous precedent, leading to the inclusion of other non-educational institutions, further diluting the education sector’s focus.

Relevant Legal Precedents

Several Supreme Court decisions provide insight into the interpretation of constitutional mandates regarding budget priorities:

  1. Philippine Constitution Association v. Enriquez, G.R. No. 113105, August 19, 1994
    • The Court ruled that the Constitution must be interpreted based on its framers’ intent, emphasizing adherence to constitutional provisions to ensure their integrity.
  2. Belgica v. Ochoa, G.R. No. 208566, November 19, 2013
    • The Court underscored the need for transparency and adherence to constitutional principles in the allocation and utilization of public funds.
  3. Sarmiento III v. Mison, G.R. No. 79974, December 17, 1987
    • This case reinforced the principle that government actions must align with constitutional directives, especially in matters of public interest and resource allocation.

Weighing the Arguments

The government’s rationale relies on a broader interpretation of education, framing PMA and PNPA as specialized educational institutions. However, critics raise valid concerns about constitutional fidelity and potential budgetary manipulation. While this decision highlights the evolving scope of education in a modern context, it risks undermining the constitutional mandate to prioritize foundational education systems.

Recommendations

  1. For the Government:
    • Clearly justify this reclassification with comprehensive legal and practical arguments, ensuring public trust and transparency.
    • Advocate for legislative amendments to explicitly define the scope of “education” under the Constitution, providing a clear legal basis for such inclusions.
  2. For Critics:
    • File a petition with the Supreme Court to clarify the constitutional interpretation of “education” in the context of budget priorities.
    • Push for reforms to ensure that the constitutional mandate prioritizes accessible and foundational education systems.
  3. For Stakeholders:
    • Foster public consultations to address concerns about budgetary priorities and institutional inclusions in the education sector.
    • Promote transparency and accountability in budget allocation to avoid perceptions of manipulation.

Conclusion

As the debate rages on, the inclusion of PMA and PNPA in the education budget highlights a critical juncture in the nation’s legal and moral compass. Will the Supreme Court’s eventual ruling strengthen the constitutional commitment to education, or redefine it in ways we never anticipated? One thing is certain: how we resolve this today will echo through every budgetary decision of tomorrow.

Louis ‘Barok‘ C. Biraogo

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