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 118 G.R. Nos. 271059, 271347, E-02472 and E-04036 b. As part of the Congress's legislative oversight, and given the distinction between spending for the deficit and spending ,.,,,. through Unprogrammed Appropriations, the conditions for the use of new income, as well as additional earnings of the Government from non-tax revenue sources, should be clearly differentiated between programmed and unprogrammed expenditures, with Congress presumptively using these neW''-'•;ss,- funds for programmed expenditures, except when there ate clear and convincing reasons, such as foreign assisted projects, for including them under Unprogrammed Appropriations. c. Congress should prescribe sufficient standards in ·terms of· prioritization for spending when there is more than one purpose under the Unprogrammed Appropriations. d. The provision for Unprogrammed Appropriations should be within the national fiscal program established in the Budgetand consistent with its nature as a narrow contingent appropriation; (2) Article VI, Section 25(1), which prohibits Congress from increasing the appropriations recommended by the president, applies to the total of programmed and unprogrammed appropriations.· (3) The increases in the Special Accounts of the General Fund are not covered by the constitutional prohibition under Article VI, Section 25(1 ), as those are existing appropriations covered by special laws. ACCORDINGLY, the Petitions in G.R. Nos. 271059 and E-02472 are GRANTED. The Petitions in G.R. Nos. 271347 and E-04036 are PARTLY GRANTED. The Court declares as unconstitutional: I. Congress's increase of the Unprogrammed Appropriations by PHP 449.5 billion, which resulted in an increase in the president's total recommended appropriations, and consequently, Republic Act :No, 1 1975 or the 2 024 General Appropriations Act; 2. Special Provisions l(a) and (b), Chapter XLIII of Republic Act No. 12314, or the 2026 General Appropriations Act; 3. Congress's increase of the Special Road Fund by PHP 17 .992 billion, which resulted in an increase in the president's total recommended appropriations, and consequently, Republic Act No. 12116, or the 2025 General Appropriations Act. f