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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. 40 / 121
•Decision 40 G.R. Nos:c 271059, 271347, E-02472 and
E-04036
amounts will be released comprehensively under the GAA as the Allotment
Order. 197 Generally, those under Programmed Appropriations are
automatically released under the General Appropriations Act as Allotment
Order (GAAAO). 198
For items requiring a SARO, including those under Unprogrammed
Appropriations, agencies are required to submit a Special Budget Request
and other budgetary requirements as applicable. 199
Once the SARO is issued, disbursement authorities such as a Notice of
Cash Allowance will be issued. The Notice of Cash Allowance specifies the
maximum amount of withdrawal that an agency can make from a g\)Vemment
bank for the period indicated.200
However, for those covered by the GAA as the allotment order, i.e.,
items not requiring compliance to some pre-conditions, agencies •are
authorized to obligate funds immediately upon the effectivity of the GAA.
Once the National Budget is approved and funds are released, the
implementing agencies become the main drivers of the budget execution ·
phase, translating allocations into tangible outcomes, including goods and
services.
Accountability
The final stage is the appraisal and evaluation of the implemented
budget for accountability and, more significantly, as feedback for the
formulation of new goals. It involves the reporting of actual performance
against plans and targets and includes periodic monitoring and review of
•agency fund utilization. • • • ' ' •
The Administrative Code, Book VI, Chapter VI requires agency heads
to develop and enforce a system for periodic measurement and evaluation of
the performance of their agencies,201 and to report on their annual performance
to the president. This begins from the agency head to the department secretary
and to the DBM, and later, from the DBM secretary to the president. Agencies
must also account for their use of public funds as authorized by Congress.
197 Id. at I 0.
198 TSN June 2, 2026, p. 43. /
'"" Detailed discussion on the Budget Process submitted by the OSG through its Subsequent Compliance
dated March 17, 2026, pp. 16-17; DBM National Budget Circular No. 595 dated Janyary 20, 2025,
Guidelines on the Release of Funds for Fiscal Year (F.Y.) 2025. . ..
2uu Depai1ment of Budget and Management, The Budgeting Process, available •at
https://www.dbm.gov.ph/wp-content/uploads/2012/03/PGB-B2.pdf (last accessed on October 6, 2026).
201 ADMINlSTRATlVE CODE, Book VI, Chapter 2, sec. 9.
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