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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. 15 / 37
Concurring and Dissenting Opinion 15 G.R. Nos. 271347, 278353, E-02472 & E-04036 normalize the situation or living conditions in areas or communities stricken by disasters, calamities, epidemics, or complex emergencies. 42 During the budget execution, the President is also constitutionally permitted, by way of exception, to transfer appropriations under strict conditions.43 This mechanism, lmown as augmentation, allows flexibility when there is deficient funding for some PAPs, on one hand, and actual savings, on the other.44 During the height of the Covid-19 pandemic, this mechanism enabled the government to utilize approximately PHP 266 billion in programmed appropriations for targeted social amelioration programs.45 Funding Source for Covid-19 Allotment Release Response (in million PHP) Discontinued P APs 266,235.3 Regular Agency Bud11:et 10,245.6 NDRRMF . ' 1,136.0 Contin11:ent Fund 553.1 UAs 96,719.9 Total 374,888.1 The Contingent Fund, Calamity Fund, and transferred appropriations are all integrated within the expenditure cap proposed by the President and approved by Congress. Unlike UAs, they are part of the govem1nent's fiscal forecast and do not rely on windfall receipts. From 2022 to 2025, the UAs authorized by Congress through the GAAs have substantially surpassed the UAs proposed by the President in the National Expenditure Program (NEP). As a result, the total appropriations (programmed, unprogrammed, and automatic) in the GAA for 2022 to 2024 exceeded the total appropriations contained in the NEP: GAA Year Unprogrammed Appropriations Amount of NEP GAA increase 2022 151,639,197,000 251,639,197,000 100,000,000,000 2023 588,162,480,000 807,162,480,000 219,000,000,000 2024 281,908,056,000 731,448,566,000 449,540,510,000 2025 158,665,456,000 531,665,456,000 373,000,000,000 42 Id., sec. 22(c). 43 CONST., art. V1, sec. 25(5) 44 See Arau/lo v. Aquino, 737 Phil. 457 (20i4) [Per J. Bersamin, En Bar.c]. 45 Department of Budget and Management, Status of COVID-19 Releases, available. at bttps:;/\nvw .Q.bm.gov .ph,iini.:kx. phpistatlJ..~.Q.f-cqyj_i;l- l ~-refoJses.