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271059/271347/E-02472/E-04036 Representative Edcel C. Lagman, substituted by Albay First District Representative Krisel B. Lagman, et al. Vs. The Congress of the Philippines, et al./Aquilino “Koko” Pimentel III and Pantaleo “Bebot” Alvarez Vs. Lucas P. Bersamin, in his capacity as executive secretary, and Amenah F. Pangandaman, in her capacity as secretary of the Department of Budget and Management/Filipinos for Peace, Justice and Progress Movement, Inc. (FPJPM), represented by its president and chairperson, Joseph F. Cadsawan, and Gloria T. Puzon, chapter Officer Vs. The House of Representatives, et al./Edgar R. Erice and Leila De Lima Vs. The Senate of the Philippines, et al. — Official PDF

271059/271347/E-02472/E-04036 — Promulgated October 7, 2026 · 2026 · Supreme Court 2026 / Decision or signed resolution

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DIGITAL P. 105 / 121
Decision 105 G.R. Nos. 271059, 271347, E-02472 and E-04036 National Commission for Culture - ,._ -,.,-~,... and the Arts (1'.roper) - National Endowment Fund for Culture and the Arts443 670,858,000 500,315,000444 575,315,000445 75,000,000 Philinnine Snace As,encv446 - - 126 , 3 I 7 , 000447 126,317,000 Budgetary Support to Government Cornorations ... Philippine Coconut Authority - Coconut Development Fund and Coconut Consumers Stabilization Fund448 71,491,000 5,400,000449 70 ,400 ,000450 65,000,000 TOTAL 5,529,306,000 18,283,976,900 12,754,670,900 Contrary to petitioner's allegations, the prohibition against increasing the presidential budget under Article VI, Section 25(1) does not apply to SAGFs, as these constitute existing appropriations. The authority for SAGFs is derived from the special law creating them. As such, SAGFs are not part of the appropriations recommended in the president's budget.' They are included in the BESF not for legislative authorization, but to provide a 'comprehensive view of the government's expenditures. Congress, in the exercise of its oversight functions, may review the . Executive's projections and make appropriate adjustments to the SAGFs based on its own determination of the expected revenue streams. Only when Congress's determination regarding the collection of more fees constitutes grave abuse of discretion may such increase be nullified. Further, as each SAGF is created by its respective law, the primary limitation is that funds earmarked by these special laws must not be diverted from their statutory purposes. Here, petitioners failed to demonstrate that the funds earmarked for each of the special purposes enumerated above were spent for purposes other than those mandated by the respective laws creating them. Parenthetically, Section 25, Chapter IV; Bobk VI of the Administrative Code explicitly prohibits Congress from increasing the "amounts specified in . special provisions beyond those proposed by the President:" 451 "' Republic Act Nos. 7356 (1992) and 10066 (2009). The Fund is sourced from the contributions of PAGCOR and share from travel tax collections in accordance with Section 20 of Republic Act No. 7356 (! 992). 444 2025 NEP, Volume lll, Special Provisions, no. I, p. 584. ·"5 2025 GAA, Volume 1-B, Special Provisions, no. I, p. 503. / 446 Republic Act No. I 1363, sec. 22(a). 447 2025 GAA, Volume l-B, Special Provisions, no. I, p. 547. 448 Presidential Decree Nos. 1234 (1977), 1854 ( 1982) and Republic Act No. 1 145 (I 954). Sourced from service fees on desiccated coconut and from levies on copra rececada in accordance with Sec. 14 of Republic Act No. 1145 (I 954) and Sec. I, Art. lll of Presidential Decree No. 1468 (1978). 449 2025 NEP, Volume Ill, Special Provisions, no. I, p. 807. 450 2025 GAA, Volume 1-B, Special Provisions, no. I, p. 633. 451 ADM. CODE ( 1987), Book IV, sec. 25.