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	GR No. 177508 2009-08-07	BARANGAY ASSOCIATION FOR NATIONAL ADVANCEMENT v. COMELEC CARPIO, J.
There is no violation of the non-impairment clause. First, the non- impairment clause is limited in application to laws that derogate from prior acts or contracts by enlarging, abridging or in any manner changing the intention of the parties.[32] There is impairment if a subsequent law changes the terms of a contract between the parties, imposes new conditions, dispenses with those agreed upon or withdraws remedies for the enforcement of the rights of the parties.[33]
	GR No. 143076 2003-06-10	PHILIPPINE RURAL ELECTRIC COOPERATIVES ASSOCIATION v. SECRETARY PUNO, J.
It is ingrained in jurisprudence that the constitutional prohibition on the impairment of the obligation of contracts does not prohibit every change in existing laws. To fall within the prohibition, the change must not only impair the obligation of the existing contract, but the impairment must be substantial.[27] What constitutes substantial impairment was explained by this Court in Clemons v. Nolting:[28]