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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. 12 / 121
Decision 12 G.R. Nos. 271059, 271347, E-02472 and
E-04036
2024 GAA. From a proposed level of PHP 282 billion in the 2024 NEP, the
Unprogrammed Appropriations surged to PHP 732 billion in the 2024 GAA.
Congress then introduced Special Provision l(d) authorizing the fund
balance of GOCCs as one of the sources of. financing for Unprogrammed
Appropriations, which was declared unconstitutional by this Court on
December 5, 2025.30
In 2026, Congress approved PHP 243.40 billion unprogrammed
appropriations,3 1 a little lower than the proposed level of PHP 249.99 billion
in the NEP. The president further vetoed PHP92.5 billion, leaving about
PHP150.91 billion of unprogrammed appropriations.32 From the list of
purposes in the NEP,33 and in the 2026 GAA,34 the following projects and
programs were left: Revised Anned Forces of the Philippines Modernization
Program; Risk Management Program; and Support to Foreign-Assisted
Projects.
30 Pimentel Ill v. Matula, G.R. Nos. 274778, 275405 & 276233. December 3, 2025 [Per J. Lazaro-Javier,
En Banc] .
.ii Petition for Certiorari and Prohibition dated January 7, 2025 (G.R. No. E-04036), p. 10.
32 Id. at 12.
:n The NEP listed the following purposes:
Strengthening Assistance for Government Infrastructure and Social PHP 80,863,172,000
Programs (SAGIP)
Budgetary Sunnort to GOCCs PHP 6,895,000,000;
Sunnort to Forei211-Assisted Proiects PHP 97,305,671,000
Program on Risk Management PHP 3,600,000-,000
Refund of the Service Development Fee for the Right to Develop the PHP 210,579,000
Nanmeidai Prooertv in Tokvo, Jaoan
Prior Years' LGU Shares PHP 14,623 000
Public Health Emergency Benefits and Allowances for Health Care and Non- PHP 6,766,760,000
Healthcare Workers
Revised AFP Modernization Program PHP 50,000,000,000
Fiscal Support Arrearages for Comprehensive Automotive Resurgence PHP 333,504,000
Strateov (CARS) orogram
Marawi Siege Victims Cornoensation Proeram PHP 2,000,000,000
Comprehensive and Adequate Insurance Protection of Strategically PHP 2,000,000,000
Important Government Assets and lnterest
34 The finalized purposes listed in Chapter XLIII of the 2026 GAA were listed as follows:
Budgetary Sunnort to GOCCs PHP 6,895,000,000;
Sunnort to Foreign-Assisted Projects PHP 97,305,671,000
Government of the Phils. Countemart of Foreign-Assisted Proiects PHP 35,7]69 481,000
Program on Risk Mana.gement PHP 3,600,000,000
Prior Years' LGU Shares PHP 14,623,000
Revised AFP Modernization Program PHP 50,000,000,000
Fiscal Support Arrearages for Comprehensive Automotive Resurgence PHP 4,320,765,000
Strateuv (CARS) program
Revitalizing the Automotive Industry for Competitiveness Enhancement PHP 250,000,000
(CARE) Program
Comprehensive and Adequate Insurance Protection of Strategically PHP 2,000,000,000
lmoortant Government Assets and Interest
For Payment of Personnel Services Requirements PHP 43,245,110,000
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