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· 45 G.R. Nos. 271059, 271347, E-02472 and E-04036 their exposure to changes in market sentiment and volatility in capital flows, and in the process contain the risk of debt crises.223 Indeed, one of the guiding principles m the government's budget process is fiscal discipline: Fiscal Discipline or spending within the means or resources available to the government. Controlling government expenditures and/or budget deficit within sustainable or manageable levels, through strategic medium-term . fiscal planning.224 . . . . . . . . The provision on Unprogrammed Appropriations must be understood within this constitutional structure. Since 1987, unprogrammed appropnat1ons have been part of the national budget/GAA. It was originally conceived as narrow contingent appropriations intended to cover possible authorization for FAPs that were not included in the proposed budget, but likely to become effectiye during the forthcoming fiscal year. Amicus curiae Diokno explains the reason for the necessity of a standby appropriations cover for F APs: F APs should be the most senior of all budget items since they involve foreign funding, usually at concessional rates given the Philippines state of underdevelopment, have undergone rigorous evaluation, and have serious external controls. FAPs undergo pre-feasibility and feasibility . , studies, detailed engineering study, and have, passed the Internal Rate of Return threshold chosen by the Department of Economy, Planning, and Development (DEPDev) Investment Coordination Committee. But despite these strong arguments for FAPs, these projects risk delay due to the constitutional requirement that "no money shall be paid out of the Treasury except in pursuance of an appropriation made by law" (Section 29[1 ], Article VJ). There are some FAPs that are in the process of being completed during the budget preparation phase but have a strong probability of completion in the budget execution phase. Hence, the need for standby appropriations for F APs that have yet to be approved during the preparation of the President's budget but are highly likely to be approved within the ensuing fiscal year. Delay in implementation could result to the payment of commitment fees to multilateral finance institutions (MF!s), such as the Asian Development Bank (ADB) or the World Bank (WB). Also, the lack of appropriations cover delays the benefits to be derived from the timely implementation of the FAPs. Project delays oftentimes upset the cost- benefit calculus of many FAPs. In recent Philippine history, as documented by the DEPDev, the Philippines has suffered extensive and costly delays in • foreign-funded projects because oflack of appropriations co'ver.225 :m Id. at 2-3. 22<1 Detailed discussion on the Budget Process submitted by the OSG through its Subsequent Compliance dated March l 7, 2026, p.3. 22s Amicus Curiae Hon. Benjamin E. Diokno's Memorandum dated July 21, 2026, p.12.