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 4 G.R. Nos. 271059, 271347, E-02472 and E-04036 Congress is constitutionally prohibited from increasing the president's total recommended appropriations in the Budget of Expenditures and Sources of Financing (BESF), which covers both programmed and unprogrammed appropriations. Republic Act No. 11975 or the 2024 General Appropriations Act (2024 GAA) is unconstitutional because the total appropriations were· increased by PHP 449.5 billion. The increases were in the unprogrammed allocations. Furthermore, unprogrammed appropnat1ons per se are ... not . unconstitutional. They become constitutionally infirm when they lack sufficient standards, effectively granting the Executive unchecked spending authority that undermines funding for programmed projects when estimated government revenues are not realized. Republic Act No. 12116 or the 2025 General Appropriations Act (2025 GAA) is likewise unconstitutional because of the increase in the programmed appropriation for Special Road Fund by PHP 17,992,085,000.00, thereby increasing the president's total proposed appropriations.The appropriation for Special Road Fund - Motor Vehicles User Charge is a line item under the Department of Public Works and Highways (DPWH). Ordinarily, Congress has the discretion to increase the allocation of the Special Road Fund. It cannot, however, reallocate statutorily earmarked Special Account in the General Fund (SAGF). However, the Administrative Code, in Section 25, limits this discretion. It could not therefore increase this SAGF without violating Article VI, Section 25 (I) of the Constitution. These consolidated cases present an opportune time to examine, reaffirm, and preserve the constitutional design and safeguards on the budgetary process, one of the most important governmental functions in our democratic state. Following the controversial transfer of the Philippine Health Corporation's "fund balance" to the National Treasury are the flood control scandal and news of excesses in the handling of public funds. Successive challenges were brought against the 2024, 2025, and 2026 budgets before this Court, primarily assailing the constitutionality of unprogrammed appropriations, as well as increases made in both unprogrammed appropriations and special accounts or funds, including the road users' tax fund, during the bicameral phase. /