When the constitutionality of a law is put in issue.

"When the constitutionality of a law is put in issue, judicial review may be availed of only if the following requisites concur: “(1) the existence of an actual and appropriate case; (2) the existence of personal and substantial interest on the part of the party raising the [question of constitutionality]; (3) recourse to judicial review is made at the earliest opportunity; and (4) the [question of constitutionality] is the lis mota of the case.”32

In this case, petitioners are challenging the constitutionality of the tax
deduction scheme provided in RA 9257 and the implementing rules and regulations issued by the DSWD and the DOF. Respondents, however, oppose the Petition on the ground that there is no actual case or controversy.

We do not agree with respondents.

An actual case or controversy exists when there is “a conflict of legal
rights” or “an assertion of opposite legal claims susceptible of judicial
resolution.”33 The Petition must therefore show that “the governmental act being challenged has a direct adverse effect on the individual challenging it.”34 In this case, the tax deduction scheme challenged by petitioners has a direct adverse effect on them. Thus, it cannot be denied that there exists an actual case or controversy."

See -
MANILA MEMORIAL PARK, INC.
AND LA FUNERARIA PAZ-SUCAT,
INC.,
Petitioners,
-versus-
SECRETARY OF THE
DEPARTMENT OF SOCIAL
WELFARE AND DEVELOPMENT
and THE SECRETARY OF THE

G.R. No. 175356
Promulgated: DECEMBER 03, 2013