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 51 G. R. Nos. 271059, 271347, E12472 ond . E-04036 Petitioners stress the fundamental structural defect of Unprogrammed Appropriations inverting the constitutional architecture of budgeting, i.e., "instead of revenues determining expenditures, expenditures are authorized in anticipation of revenues whose existence is speculative and contingent. This reverses Article VII, Section 22 and transfers to the Executive the authority to decide when, whether and to what extent public funds may be spent."243 Respondents counter that the prov1s1ons on Unprogrammed Appropriations provide for definite and identifiable sources of financing. • •• • They argue that what Section 22 requires is that the sources of financing include "receipts from existing and proposed revenue measures." The use of "include" suggests that the enumeration is non-exhaustive, i.e., the president may identify other sources of financing. 244 Section 22 imposes a disclosure standard, not an availability standard; the conjunction "and" emphasizes two separate categories of information that the president must submit to Congress.245 It does not impose a requirement that the revenues must exist at the point of submission of the budget.246 Moreover, the language of Section 22 embraces both prospectivity and contingency in allowing sources of financing to include receipts from proposed revenue measures. So as not to unduly hamstring the budgeting process, "a fairly reasonable allowance for estimation is accepted. But, the flexibility is nonetheless limited."247 "Section 22 prevents the executive from proposing a budget based on unfounded projections."248 Article VII, Section 22 of the Constitution states: Section 22. The president shall submit to the Congress within thirty· days from the opening of every regular session, as the basis of the general appropriations bill, a budget of receipts and expenditures and sources of financing, including receiptsfi-om existing and proposed revenue measures. (Emphasis supplied) The budget to be submitted by the president includes receipts from existing and proposed revenue measures. The tenn "proposed revenue measure" is not certain and definite because it will still have to go through the legislative process before it is passed into law. This reasonably allows the Executive some flexibility in managing the budget and proposing appropriations to cover agency expenditures contingent on the availability of additional resources. 2~.:! Id. at 30. '" Respondents' Comment dated March 23, 2026, p. 46. 245 Id. at 47. 24(, Id. w Id. at 48. 24~ Id.