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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. 111 / 121
Decision 111 G.R. Nos. 271059, 271347, E-02472 and
E-04036
The November 7, 2023 Senate Committee Report No. 155468 shows
changes to almost all appropriations for departments and agencies, except for
the following departments and funds:
l. Office of the President
2. Office of the Vice President
3. Department of Agrarian Reform
4. Department of Energy
5. Department of Environment and Natural Resources469
6. Department of Finance
7. Department of Public Works and Highways
8. National Economic and Development Authority470
9. Presidential Communications Office471
10. Office of the Ombudsman
11. Special Purpose Funds
a. Budgetary Support to Government Corporations472
b. Allocations to LGUs
c. Contingent Fund . .
d. National Disaster Risk Reduction and .Management Fund·
e. Pension and Gratuity Fund •
f. Revised AFP Modernization Program
There were changes in the allocations under Unprogrammed
Appropriations, 473 with the total amounts of increases and decreases being the
same at PHP 23. billion, resulting in the same net allocation of PHP 281.9
billion.
Thus, since the House-approved and Senate-approved versions of the •
2024 General Appropriations Bill are not exactly alike, the Bicameral
Conference Committee was necessary to reconcile the disagreeing provisions.
In this regard, Tolentino v. Secretary of Finance474 should not be read
as giving unfettered discretion to the Bicameral Conference Committee. This
compiittee will only ~xist if there _are differiq.g provisions in the House and
468 Annex 3, OSG Consolidated Comment dated May 27, 2024 in G.R. Nos. 271059 & 271347.
469 Only the Office of the Secretary was changed. The allocations for Environmental Management Bureau,
Mines and Geoscience Bureau, National Mapping and Resource Information Authority, National Water
Resources Board, Palawan Council for Sustainable Development Staff remained the same.
•170 Only the Office of the Secretary and Philippine Statistics Authority were changed. The allocations for
Cornm·ission on Population and Development, Philippine National Volunteer Service Coordinating
Agency, Public-Private Partnership Center of the Philippines, Philippine Statistics Research and
Training Institute, Tariff Commission remained the same.
471 Only the PCO Proper was changed. The allocations for Bureau of Communications Services, National
Printing Office, News and Information Bureau, Philippine Information Agency, Presidential Broadcast-
Service - Bureau of Broadcast Services, Presidential Broadcast Staff remained the same. •
472 Budgetary support to the Depa1iment of Energy, Department of Environment and Natural Resources,
Department of Human Settlement and Urban Development, Department of Trade and Industry, Department of Transportation,. and Others remained the same. I
473 The Senate Committee Report does not show the specific projects, activities and programs under
Un programmed Appropriations that were changed.
474 305 Phil. 686 (1994) [Per J. Mendoza, En Banc].
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