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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. 24 / 36
Concurring and Dissenting Opinion 24 G.R. Nos. 271059, 271347,
E-02472 & E-04036
condition of the Treasury at the end of the fiscal year in
progress, and the estimated condition of the Treasury at the end
of the ensuing fiscal year, if the financial proposals contained
in the Budget are adopted, showing, at the same time, the
unencumbered and unobligated cash resources;
(5) all essential facts regarding the bonded and other long-term
obligations and indebtedness of the Government; and
( 6) such other finandal statements and data as are deemed
necessary or desirable in order to make known in all practicable
detail the financial conditions of the Government. 95
Republic Act No. 992 also mandated a balanced budget, but
• emphasized that this restriction does not impair the power of the Congress to
enact revenue and appropriation bills, nor the authority of the President to
propose special revenue and appropriations bills, after the submission of th.e
budget.96
The Revised Budget Act was then amended by Presidential Decree No.
999,97 which refined and added fun.ctions and powers of the Budget
Comrnission,98 but nevertheless maintained the basic principles of budgeting
of the Revised Budget Act.
On July 3 0, 1977, Presidential Decree No. 1177, also known as the
Budget Reform Decree of 1977, was passed and superseded the Revised
Budget Act. It aimed to institutionalize budgetary innovations developed
within the context of the 1973 Constitution.99 Under Presidential Decree No.
U 77, the policy is for the national budget to be formulated as an instrument
. for t~e attainment of n.ational development goals ?nd as part of the planning-
programming-budgeting continuum. To this end, it was required that "levels
of revenue, expenditure Md debt be established in relation to macro-economic
targets of growth, erpployment levels, and price level change, and shall be
developed consistent with domestic arid foreign debt, domestic credit and
BalMce of Payments objectives for the budget period." 100 As to the form Md
content of the budget, Presidential Decree No. 1177 adopted the requirements
first introduced by the Revised Budget Act and also emphasized that the
amount of proposed appropriations for current operations and capital outlays
of the government shall be covered by ordinary income and t.liat "no
appropriation for MY expenditure, the amount of which is not covered by the
estimated income from the existing sources of revenue or available current
surplus, may be proposed, unless it is supported by a proposal creating an
additional source of funds sufficient to cover the same."101 Under Presidential
95 Republic Act No. 922 (1954), sec. 8c
96 Republic Act No. 922 (1954), sec. 13.
97 Passed on September 16, 1976.
' 98 Pi"esidential Decree No: 999 ( 197 6 ), sec. 3.
99 Whereas clauses, Presidentiel Detl"ee No. 1177.
100 Presidential Decree No. 1177 (1977), sec.·,t
101 Presidentia! Decree No. Nti. J 177 (1977), se~~- 15.
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