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 48 G.R. Nos. 271059, 271347, E-02472 and E-04036 appropriations. Second, it violates the constitutional requirement of including sources of funding as previously discussed. Lastly, it is ambiguous, as Unprogrammed Appropriations, by their nature, are broad, conditional, and , indeterminate. It is not supported by concrete expenditure programs at the time of enactment, and merely authorizes future spending contingent upon executive certification.232 Respondents counter that similar to other provisions in the 2026 GAA, the Unprogrammed Appropriations also identify the specific purposes/specific object of expenditures, amount and sources of funds. It is particular, unambiguous, and appropriate; hente, germane to the 2026 GAA.233 The 2026 GAA specifically provided the amount of money needed for each of the enumerated programs/projects, e.g., (a) Support to Foreign- Assisted Projects; (b) Program on Risk Management; and (c) Revised AFP Modernization Program.234 Respondents contend that the enforcement of the unprogrammed .. appropriation in the 2026 GAA is clearly spelled out. Special Provision 1 specifies the conditions when these funds may be availed of for the specified purposes. The conditional nature of the funds does not make the unprogrammed appropriations a "rider."235 Lastly, respondents argue that petitioners' claim that the unprogrammed appropriations should instead be included in ,a special appropriations bill is impractical and fiscally unsound. They contend that considering the lengthy process. of passing a bill, it is appropriate for the government's programs placed in the unprogrammed appropriations to be . immediately allocated funds in case of unexpected, excess, or windfall revenue.236 The Unprogrammed Appropriations under the 2026 GAA is nofa rider. The general constitutional prohibition on bills containing riders is found in Article VI, Section 26(1) of the Constitution, which requires that "every bill passed by the Congress shall embrace only one subject which shall be express in the title thereof." Meanwhile, Article VI, Section 25(2) of the Constitution provides for special scrutiny regarding riders in appropriation bills: m Petition for Certiorari and Prohibition (G.R. No. E-04036), pp. 34--41. D:i Respondents' Comment dated March 23, 2026, p. 82. 2:,4 Id. 235 Id. at 86. 2Jc, Id. at 87.