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 50 G.R. Nos. 271059, 271347, E-02472 and E-04036 that is conditioned on the occurrence of specified events. It is unambiguous ••• because its availability and use are apparent in Special Provision 1 of Chapter XLIII of the 2026 GAA, and it does not necessitate further reference to details outside the 2026 GAA. The provisions on Unprogrammed Appropriations in the 2026 GAA are appropriate as they do not have to be the subject of separate legislation because their function is precisely to serve as standby authorization for funding of specified purposes, programs and projects, contingent on the availability of certain revenues. Moreover, Book VI, Chapter 4, Section 27 of the Administrative Code of 1987 provides: SECTION 27. Supplemental Appropriations. -All appropriation • proposals shall be included and considered in the budget preparation process. After the President shall have submitted the Budget, no supplemental appropriation measure supported .from existing revenue measures shall be passed by the Congress. However, supplemental or deficiency appropriations involving the creation of new offices, programs . or activities may be enacted if accompanied and supported by new revenue sources. (Emphasis supplied) The law requires that all appropriation proposals must be included aI).d considered in the budget preparation process. Unprogrammed Appropriations. are part and parcel of the appropriation proposals. As a result, the inclusion of Unprogrammed Appropriations in the budget proposal, then later on in the 2026 GAA, is proper and appropriate. It is not a rider. V(A) Petitioners Erice and De Lima contend that the unprogrammed appropriations in the 2026 General Appropriations Act are unconstitutional, not merely because of its size or contingency, but because it negates the very concept of a constitutional budget which, under Article VII, Section 22, requires that the General Appropriations Bill be based on a BESF.241 Petitioners contend that the General Appropriations Bill is meant to rest on a fiscal program that is matched with identifiable sources of financing, n_ot on spending authority dependent on contingencies that remain uncertain at the time of enactment. These contingencies, petitioners argue, are not actual ;J sources of financing at the time of enactment, but speculative future / possibil ities.242 241 Petition for Certiorari and Prohibition (G.R. No. E-04036), p. 2. 142 /d.at3!-32.