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 13 G.R. Nos. 271059, 271347, E-02472 and E-04036 With the magnitude of the amounts involved and the risk of unconstitutional release and expenditure of public funds, the Petitions were filed questioning the constitutionality of the provision for Unprogrammed Appropriations and the increases thereto. SAGF and Special Road Fund The Petition in G.R. No. E-0247235 assails the constitutionality of Republic Act No. 12116 (2025 GAA) based on the upward adjustment made by Congress through the Bicameral Conference Committee to the Special Accounts in the General Fund (SAGF) and the DPWH's Special Road Fund, which allegedly violated Article VI, Section 25(1) of the 1987 Constitution.36 Respondents, through the OSG, filed their Comment to the Petition.37 A SAGF is a fund where "proceeds from specific revenue measures and grants eannarked by law for specific priority projects are recorded."38 Meanwhile, the Special Road Fund is a SAGF, where collections of Motor Vehicle User's Charges by virtue of Republic Act No. 8794,39 as amended, and deposited in the National Treasury, are credited and earmarked solely for the construction, upgrading, repair, and rehabilitation of roads, bridges, and road drainage.40 On July 29, 2024, the DBM submitted the 2025 NEP to Congress, amounting to PHP 6,352,390,000,000.00, broken down as follows: 41 Description .Amountin 2025 NEP New General Appropriations PHP 4,405,895,827,000 Automatic APnronriations PHP 2,105,159,629,000 Total Available APnropriations PHP 6,511,055,456,000 Less: Unprogrammed Annropriations PHP 158,665,456,000 Total Exnenditure Prol!ram FHP 6,352,390,000,000 Automatic appropriations are further broken down into the following components, with the SAGF amounting to PHP 27,352,123,000.00:42 35 Titled Filipinos for Peace, Justice and Progress Movement, Inc. v. House of Representatives. Petition for CerthJrari and Prohibition (With Urgent Prayer for the Issuance of a Temporary Restraining Order and/or Writ of Preliminary Injunction) was filed on September 17, 2026. 3<, The Conoress may not increase the appropriations recommended by the President for the. operation of· the Gove7-nment as specified in the budget. The form, content, and manner of preparation of the bhdget shall be prescribed by law. 17 Comment filed by'the OSG on November 7, 2025. ,33 Glossary of Terms, 2025 Budget of Expenditures and Sources of Financing F.Y. 2025, P: 899. 39 An Act Imposing a Motor Vehicle User's Charge on Owners of All Types of Motor Vehicles and 0 ther /1 Purposes (2000). '° [mplementing Rules and Regulations of Republic Act No. I 1_239 (20 I 9), sec. 3._ .. 1 . . 41 2025 NEP, Annex A, Summary of Appropriations and Obhgat10ns of the Nat10nal Government C.Y. 2023-2025, Introduction Table I & Detailed Annexes, pp. 1105, 1121. 42 Petition (G.R. No. E-02472), par. 5.30.