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 20 G.R. Nos. 271059, 271347, E-02472 and E-04036 , Third, whether unprogrammed appropriations, as a means of allocating and determining the national budget, are constitutional. Fourth, whether the unprogrammed appropriations under the 2026 GAA are unconstitutional: a. whether it violates Article VU, Section 22 of the 1987 Constitution; b. whether it violates Article VI, Section 25( 4) of the 1987 Constitution; c. whether it is a "rider" provision that violates Article VI, Section 25(2) of the 1987 Constitution; d. whether it violates the constitutionally guaranteed separation of government powers; and e. whether its inclusion in the National Budget amounts to an undue delegation of Legislative powers. Fifth, whether Congress acted with grave abuse of discretion when it increased the following: a. the Unprogrammed Appropriations in the 2024 General Appropriations Act by PHP 449.5 billion; b. the Special Accounts in the General Fund allocations from PHP 27 .352 billion to PHP 40.107 billion beyond the amounts submitted by the president in the 2025 General Appropriations Act; c. the line-item appropriation of the Department of Public Works and Highways on the Special Road Fund by PHP 17.992 billion. Sixth, whether the Legislative branch may validly move programs, activities, and projects from programmed appropriations to unprogrammed appropriations, and vice versa. Seventh, whether the Bicameral Conference Committee exceeded its authority when it increased the Unprognunmed Appropriations in the 2024 General Appropriations Act by PHP 449.5 billion considering that there is no difference in the level of Unprogrammed Appropriations in the House and Senate versions of the bill. 112 Eighth, whether the doctrine of operative fact applies. 112 See Petition dated January 15, 2024 in G.R. No. 271059 filed by Petitioners Edee! C. Lagman, Rep. Gabriel H. Bordado Jr., and Rep. Mujiv S. Hataman, pp. 22-26.