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271059/271347/E-02472/E-04036 Concurring and Dissenting Opinion: Justice Jhosep Y. Lopez — Official PDF
271059/271347/E-02472/E-04036 — Promulgated October 7, 2026 · 2026 · Supreme Court 2026 / Separate opinion
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DIGITAL P. 15 / 36
Concurring and Dissenting Opinion 15 G.R. Nos. 271059, 271347,
E-02472 & E-04036
the govermnent will then meet and hannonize their proposed budgets to meet
target outcomes.62
By February to March of the prior fiscal year, the implementing
agencies prepare and deliberate on the forward estimates or current costs of
their ongoing programs and projects and submit these for the Tier 1 stage of
the 2 Tier Budget Approach. In April of the same year, the Budget Priorities
Framework is released, which compiles the economic forecasts and fiscal
targets for the budget year, the total cost of ongoing spending under Tier I,
and identifies available resources for new programs and projects,· as well as
the expansion of existing ones. The Framework also defines priority sectors
• and' locations, as well as other guidelines that agencies. must comply with
when preparing their Tier 2 budget proposals. After further consultations with
civil society organizations, Regional · Development Councils, and other
affected entities, the implementing agencies submit their proposed Tier 1 and
Tier 2 budgets to the DBM. The DBM, in coordination with and with the
assistance of the NEDA Investment Coordination Committee, DBCC
Subcommittee on Program & Project Appraisal, NEDA Infrastructure
Committee, GCG, DoF, and the MITRI, for projects under their respective
jurisdiction,63 then deliberates and reviews the Tier 2 proposals of the
imple:menting agencies and forwards the budget to the President and the
Cabinet for approval. Once approved, the DBM validates the proposals and
consolidates them into the BESF.64 The BESF thus contains the
macroeconomic assumptions, public sector context, and the breakdown of the
expenditures and funding sousces for the fiscal year and the two previous
years.65 •
In addition to •the BESF, the President 'also' submits the NEP to
Congress, which consists largely of the BESF's expenditure component. The
NEP lays down the details of the government's ailotted spending for the
programs, projects, and activities (PAPs) of departments and agencies. It is
submitted in fhe form of a proposed general appropriations bill and ultimately
serves as the basis for the issuance of a legislated national budget. 66
The expenditures under the NEP may be classified as (1) Programmed
General Appropriations, a11d (2) Automatic Appropriations. Programmed
General Appropriations are allocations for the national government's
operating expenses s.11.d for the programs, projects, and activities of
implementing agencies, It also includes allocations for Special Purpose Funds,
which are used for specific purposes, such as the Allocation to Local
Government Units, the National Disaster Risk Reduction and lvfanagement
G2 Budget Cycle, DB1v1 We:bsile, https:/i'WvVw.dbm.gov.ph/wp~contCnt/up}oads/Executive20%Summary/
20,16/Budget%20Cycle.pdf; last accessed on October l0, 2024. •
63 Glossary of Terms, BESF 2024.
64 Budget Cycle, DBM Website, https://www.dbm.gov.ph/wp-content/uploads1Executive20%Summaiy/
2016/Budgct'7020Cyc1e.pdL last auccs:sed on OLtob{;r 101 2024.
65 Art11.1lio v. President Aq11ino_ 111,737 PhiL 457 (2014) j.Per J. BersarniP... En Banc].
66 Id at 543.
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