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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. 109 / 121
Decision 109 G.R. Nos. 271059, 271347, E-02472 and
E-04036
This occurred with the Motor Vehicle User's Charge (MVUC) under RA
11239 (amending RA 8794), which consolidated previously separate trust
accounts into a single special account and mandated its inclusion in the
GAA. This reclassified the MVUC from SAGF to UI.461
As a line item in the DPWH budget, the Special Road Fundforms part
of the appropriations subject to the budgetary ceiling under Article VI, Section
25(1) of the Constitution, • •
Under the 2025 NEP, the New General Appropriations, which are the
sum of programmed and unprogrammed appropriations, amounted to PHP
4.406 trillion.462 Meanwhile, under the 2025 GAA, the New General
Appropriations amounted to PHP 4.779 trillion.463
Thus, Congress's increase in the appropriation for the Special Road
Fund under the Motor Vehicle User's Charge Tax by PHP 17,992,085,000.O0
is unconstitutional.
The Bicameral Conference Committee exceeded its authority when it·
increased the Unprogrammed Appropriations in the 2024 GAA by PHP 449.5
. billion.
The Bicameral Conference Committee was constituted to settle the
disagreeing provisions in the versions of the two houses of Congress.
The respective Internal Rules of both Houses provide:
Rule X, Section 62 of the Rules of the House of Representatives state:
Section 62. Conference Committee. - In cases where the House does not
agree with the Senate on any amendments to any House bill or joint
resolution, or where the Senate has approved a similar bill to a House-
approved bill, and these measures have conflicting provisions, differences
may be settled by conference committees composed of representatives
from both chambers.
464
Rule XII, Sec. 35 of the Rules of the Senate states:
461 Id.
462 2025 National Expenditures Program, Introduction.
"" 2025 GAA.
464 Rules of the House of Representatives (2022), m,ai/able . . at .
https://docs.congress.hrep.online/downloaci/docs/hrep.house.rules.adopted.ebook.pdf (last accessed on
October 6, 2026)
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