271059/271347/E-02472/E-04036 Concurring and Dissenting Opinion: Justice Maria Filomena D. Singh — Official PDF

Concurring and Dissenting Opinion 12 G.R. Nos. 271347, 278353, E-02472 & E-04036 opportunity to review it and prepare a Veto Message, where budget items are subjected to line-item veto, or are identified for conditional implementation.22 The next phase is budget execution. Here, the DBM is vested with the primary authority on how the GAA is to be implemented. During this phase, the DBM performs the following procedures: (a) issue the programs and guidelines for the release. of funds; (b) prepare an Allotment and Cash Release Program; (c) release allotments; and (d) issue disbursement authorities. The issuance by the DBM of the Agency Budget Matrix or the Special Allotment Release Order authorizes agencies to incur obligations on behalf of the Govenunent in order to implement their PAPs. 23 Finally, budget accountability pertains to the monit01ing of )low funds have been effectively and efficiently utilized to achieve the State's socio- , ecoi:omic goals by alklwing the DBM to asses.s tµe performance of agencies during the fiscal year for the purpose of implementing reforms and establishing new policies.24 It includes the power of the Conunission on Audit to examine the accounts of each government agency and instrumentality, to ascertain whether public funds were in fact utilized for the purpose for which they had been intended, and to prevent and disallow irregular, unnecessary, excessive, extravagant, or unconscionable expenditures of government funds.25 This leads us to the question of where the UAs fit in the budget cycle considering their unique nature and conditional implementation. Historical background and rationale of unprogrammed appropriations UAs are a peculiar feature of the Philippine public budget. Defined as ' a "standby" legislative authority to incur additional spending obligations,26 their disbursement is conditioned upon the occurrence of certain fiscal conditions specified in the GAA. Unlike programmed appropriations, UAs pertain to P APs which are unsupported by current financing and revenue sources. Since they do not have guaranteed funding, UAs are not a standby fund. UAs are supposed to provide flexibility in budget execution. In the early years from their conception in 1987, U As primarily served as contingent 22 Id. at 547-549. " Id. at 550-552. 24 Id. at 552. 25 Chozas v. Commission on Audit, 864 Phil. 733, 752 (2019) [Per J. A. Reyes, Jr., En Banc]. . 26 Department of Budget and Management, Glossary of Terms, available at https;//www.dbm.gov.ph/V1<'P"' content/uploads/BESF/BESF2026/GLOSSARY.pdf