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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.
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