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

Decision 114 G.R. Nos. 271059, 271347, E-02472 and E-04036 .·• . . Certainly, the absence of any record 9f ~hat transpired during the Bicameral Conference Committee proceedings does not meet this requirement. Even the Bicameral Conference Committee report was devoid of any explanation for the increases and decreases in the budget items, as required under the Rules of the House and Senate: Under these Rules, the BiCam is required to prepare, approve, and submit only a Bicameral Conference Committee Report (Report). The Report must contain a clear comparative presentation of the provisions agreed upon by the conferees, identify the amendments and reconciled provisions adopted by the BiCam, and include an explanatory statement setting forth the reasons/or the changes embodied in the final version ofthe bill. Upon approval by the conferees and subsequent ratification by both Chambers, the Report becomes the official record of the BiCam's work and further considered in the enactment of the reconciled measure.477 The Bicameral Conference Committee increased the Unprogrammed Appr()priations by PHP 449.5 billion.478 On the other hand, the Programmed Appropriations were increased and decreased by PHP 564.5 billion, resulting. in a net effect of no change in its level. Consequently, the president's proposed budget ceiling was increased by PHP 449.5 billion, in violation of Article VI, Section 25(1) of the Constitution. Ratification by both Houses of Congress will not cure the defect of the action taken by the Bicameral Conference Committee. Further, an exception to the enrolled bill theory and the general rule of restraint on the Court's judicial review over the internal processes oc procedures of Congress is, as declared in Arroyo v. De Venecia, 479 where there was a violation of a constitutional provision or the rights of private individuals. the BI CAM Report aod the joint explanation which are all that are required under their ru \es, Your Honor. J. Caguioa: Whatever explanations they have for not supplying it or whether or not, in fact they don't have copies, all of that can be contained in a manifestation sworn to by them. Sol. Gen.: Your Honor, I will relay you ... (Interrupted) ... J. Caguioa: I think this is the directive of the Court already. Sol. Gen.: Yes, Your Honor. .I. Caguioa: We want to know whether or not these documents exist or do not exist, or whether these documents do exist, but they don't want to give it to us because of their institutional concerns. Sol. Gen.: Your Honor, based on our discussion, there are really no documents, Your Honor.. J. Caguioa: Based on your discussion, but I want to hear it from the house's mouth under oath. Sol. Gen.: Yes, Your Honor. (TSN July 14, 2026 Oral Arguments, pp. 8- I!). 477 OSG Compliance, July 29, 2026. . 478 Certified True Copy of the Bicameral Conference Committee Rep01t on the 2024 Nat10nal Budget. 479 343 Phil. 42 (1997) [Per J. Mendoza, En Banc].