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 31 G.R. Nos. 271059, 271347, E-02472 and E-04036 constitutional department or organ, but also the "principles on which [our] government is founded." 163 Given the foregoing, the president has the prerogative to determine whether a public calamity or emergency exists in order to certify a bill as urgent. The terms "public calamity" and "emergency" in constitutional law may be interpreted as intentionally broad to give the president the necessary flexibility during unforeseen crises. As rightly observed by Chief Justice Gesmundo, generally, both the president and Congress are given wide discretion to determine if a law requires immediate enactment, "given that the operation of Article VI, Section 26(2) [of the Constitution] primarily affects the manner by which they are able to perform their duty of crafting and executing laws."164 While presidential certifications of urgency are subject to judicial review on the grounds of grave abuse of discretion, the challenging parties· bear the burden of demonstrating in clear, convincing, and unmistakable terms how the presidential certification of urgency constitutes a grave abuse of discretion. In this case, petitioners merely pointed out the irregularity of the budget processes and the constitutional provision which provides for the automatic reenactment of the previous general appropriations law when the ensuing year's appropriations bill is not passed on time. These assertions are insufficient given that the Executive may want to have its spending authorized for various justifiable reasons, specifically to meet and prepare for unforeseen contingencies such as disasters and global events. We take judicial notice of the fact that "Philippines ranks among the most disaster-prone countries . globally due to its high levels of exposure and v.ulnerability to hazards." 165 Our country is also one of the most at risk due to the continuing conflagration in the Middle East, 166 climate change, and persistent socio-economic challenges. 167 Moreover, even with a presidential certification, it is up to the leadership of both houses of Congress to decide whether they will need some more time for their members and constituents to peruse the General Appropriations Bill after the third reading or submission of the Bicameral 163 Manila Prince Hotel v. Government Serv;ce Insurance System, 335 Phil. 82, IOI (1997) [Per J. Bellosillo, En Banc]. H,4 C.J. Gesrnundo, Concurring Opinion, p. 8. 165 Asian Disaster Reduction Center, !n.fbrmation on Disaster Risk Reduction of the Member Countries, Philippines, available at https://www .adrc.asia/nationinformation.php?NationCode=608&Lang=en (last accessed on August I 0, 2026). __ 166 IIRE Manila, On the Middle East and the Philippines, March 19, 2026 available at https://internationalviewpoint.org/On-the-Middle-East-crisis-and-the-Philippines (last accessed on August 10, 2026). . . , . , . . . 167 Organization for Economic Cooperation and Development, OECD Economic Surveys: I'h;/ippines 2026, OECD Publishing Paris available at https://doi.org/10.1787/f0e0c58 l-en (last accessed on August I 0, 2026).