Court decisionSource checked
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
Source checked. The source check identifies the document; it does not verify every transcribed word or its current legal effect. Recovered or scanned text may contain errors. Compare the wording and subsequent history with the linked legal source.
DIGITAL P. 42 / 121
Decision 42 G.R. Nos. 271059, 271347, E-02472 and
E-04036
Third, that Congress may not increase the appropriations recommended
by the president for the operation of the government under Article VI, Section
25(1).
In terms of preparation, Article VII, Section 22 states that the president
shall submit a BESF. Amicus curiae Florencio "Butch" Abad explains the
implications of this constitutional provision:
Significantly, Article VII, Section 22 requires not merely proposed
expenditures, but also their corresponding sources of financing. The
Constitution therefore recognizes that expenditures cannot responsibly be
evaluated apart from the revenues, borrowing requirements,
macroeconomic assumptions, fiscal targets, and financing strategy that •
sustain them.
The constitutional submission is thus not a collection of separate
financial documents. It is an integrated fiscal proposal presented to
Congress as the constitutional basis for legislative deliberation.
By requiring expenditures together with their corresponding sources
of financing, Article VII, Section 22 recognizes that fiscal policy must be
evaluated as an integrated whole.206
Implicit in the submission of a BESF is the requirement that the national
budget be a financed fiscal program,207 although not necessarily a balanced
budget. In fact, through the years there has been a shift in expenditure policy
. from. a balanced budget208 to an unbalanced. budget.209 However, while
206 Amicus Curiae Florencio "Butch" Abad's Undated Memorandum, pp. 6-7.
207 TSN, April 7, 2026 Oral Arguments, p. 44. Amicus Curiae Florencio "Butch" Abad's opening statement.
"" Republic Act No. 992 ( 1954), sec. 13, the Revised Budget Act provides:
SECTION 13. Balanced Budget.- The ordinary income shall be used primarily to provide for the
current operation of the Government. Except in case ofa national emergency or serious financial stress,
the existence of which has been duly proclaimed by the President, the total authorized appropriations
for the current operahons shall not exceed the ord;nary income; and, unless extraordinary circumstances
justify it, 1he total esthnated ordinary income shall not only cover the total estimated appropriations for
current operations and capital outlays hut it shall leave a reasonable surplus besides.
No appropriations for the current operations and capital outlays of the Government shall be proposed,
unless the amount involved is covered by the ordinary income, or unless it be supported by a proposal
creating an additional source of funds or revenue, sufficient to cover the same. Likewise, no
appropriation for any other expenditures, the amount of which is not covered by the estimated income
from the existing sources of revenues or available cun-ent surplus, may be proposed unless it be
supported by a proposal creating an additional source of fund sufficient to cover the same.
The proposals creating additional sources of fund shall be prepared in the form of revenue bills which shall be appended to the Budget. f
209 ADMINISTRATIVE CODE, Book VI, Chapter 3, sec. 13 provides:
SECTION 13. Budget levels. -The ordinary income of government shall be used primarily to provide
appropriations for cu1Tent operations, except in case of a national emergency or serious financial stress,
the existence of which has been duly proclaimed by the President.
The level of aggregate revenue, expenditure and debt shall be jointly recommended to the President by
the Department of Budget and Management, the Department of Finance, the National Economic and
Development Authority and the Central Bank of the Philippines, acting within the Development Budget
Coordination Commillee o{the National Economh: and Developmenl Authority.
No appropriations for curr~nt operations and capital outlays of the Government shall be proposed unless
the amount involved is covered by the ordinary income, or unless it is supported by a proposal creating
additional sources of funds or revenue, including those generated from domestic and foreign borrowings,
sufficient to cover the same. Likewise, no appropriation for any expenditure, the amount of.which is not·
covered by the estimated income from the existing sources of revenue or available current surplus, _may
If your browser cannot display the PDF, use Download original. Original access follows the same document permissions.