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271059/271347/E-02472/E-04036 Concurring and Dissenting Opinion: Justice Maria Filomena D. Singh — Official PDF
271059/271347/E-02472/E-04036 — Promulgated October 7, 2026 · 2026 · Supreme Court 2026 / Separate opinion
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DIGITAL P. 11 / 37
Concurring and Dissenting Opinion 11 G.R. Nos. 271347, 278353,
E-02472 & E-04036
Budget preparation is the initial phase where the Department of Budget
and Management (DBM) issues the Budget Call to all agencies and
instrumentalities of the government, requesting for the latter to submit their
budget proposals. The Budget Call contains the parameters set by the
Development Budget Coordination Committee (DBCC), a vital group within
the Department of Economy, Planning and Development and composed of the
country's economic managers, as well as policy guidelines and procedures to
aid government agencies in the preparation and submission of their budget
proposals. The DBM then consolidates such proposals into the National
Expenditure Program (NEP) and the Budget of Expenditures and Sources of
' Finai1cing (BESF). These documents are then presented to the President and
the Cabinet for further refinements. Once the NEP and BESF are approved
by the President, they will be submitted to Congress as the basis of the general
appropriations bill (GAB).21
The BESF embodies the macroeconomic parameters, public sector
financial position, projected revenue collections, desired expenditure levels,
and budget framework. It also indicates the budget sensitivity, i.e., how the
proposed budget will react or be affected by the macroeconomic parameters.
The BESF gives Congress the overall fiscal picture in the medium term. It
does not contain a detailed list of PAPs.
The NEP, on the other hand, contains the list of PAPs. It itemizes each
expenditure, e.g., construction and rehabilitation of roads, school-based
feeding program, social pension for indigent senior citizens. It specifies the
, corr~sponding amo:unt of fundi:ng recommencle<l by the .President for each
item. The NEP is a consolidation of all government agency budget proposals
based on the technical and financial assessment of PAPs, feasibility studies,
past performance, and other factors to justify their funding.
The budget legislation or authorization phase covers the time the NEP
and BESF are received by Congress, up to the President's approval of the
GAA. The Appropriations Committee of the House of Representatives
schedules and conducts budget hearings to examine the programs, activities
and projects (PAPs) of the different agencies and instrumentalities, which will
all be consolidated into the GAB. The GAB is then sponsored in the plenary
of the House, and upon approval on third reading, shall be transmitted to the
Senate. The Senate Finance Committee may already conduct its own budget
hearings, but it can only submit to the Senate plenary the proposed
ainendments to the GAB upon formal transmission of the GAB by the House.
Both chambers of Congress will then constitute a Bicameral Conference
Committee (BCC) for the purpose of harmonizing the disagreeing provisions
' of each House's versi~n of the GAB. This "harmonized" GAB, after approval
of each House, shall be transmitted to the President, who will then have the
" Id. at 542-543.
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