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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 On July 3 0, 1977, Presidential Decree No. 1177, also known as the Budget Reform Decree of 1977, was passed and superseded the Revised Budget Act.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.