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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
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DIGITAL P. 53 / 121
Decision 53 G.R. Nos. 271059, 271347, E-02472 and
E-04036.
Thus, for triggers (a) and (b ), the source of funding would be excess
collections from individual non°tax revenue sources or any new revenue. For
trigger ( c ), the source of funding would be approved foreign loans.
In Araullo v. Aguino 111,254 one of the sources of funding ~e
Disbursement Acceleration Program is the unprogrammed funds under the
2011, 2012, and 2013 GAAs. The contention of therein respondents is that new
revenues from sources not originally considered in the BESF warrant the
release of unprogrammed funds. Rejecting respondents' stance, this Court
explained that new revenue per se is not enough, and that the basic condition
of total revenue collections exceeding the total revenue targets must stilt be
complied with. The Court emphasized that unprogrammed funds, as
standby appropriations, must be released only when there are revenueJ in
excess of the total revenue targets stated in the BESF:
The present controversy on the unprogrammed funds was rooted in
the correct interpretation of the phrase "revenue. collections should exceed
the original revenue targets. " The petitioners take the phrase to mean that
the total revenue collections must exceed the total revenue target stated in
the BESF, but the respondents understand the phrase to refer only to the
collections for each source of revenue as enumerated in the BESF, with the
condition being deemed complied with once the revenue collections from a
particular source already exceeded the stated target.
Thus, when the Court required the respondents to submit a
certification from the Bureau of Treasury (BTr) to the effect that the revenue
collections had exceeded the original revenue targets, they complied by
submitting certifications from the BTr and Department of Finance (DOF)
pertaining to only one identified source of revenue - the dividends from
the shares of stock held by the Government in government-owned and
controlled corporations.
The certifications reflected that by collecting dividends amounting
to P[HP] 23.8 billion in 2011, P[HP] 19.419 billion in 2012, and P[HP]
12.438 billion in 2013 the BTr had exceeded only the P[HP] 5.5 billion in
taruetb revenues in the. form of dividends. from stocks in each. of, 2011 and
• ' 2012, and only the P[HP] 1() billion in target revenues in the form of
dividends from stocks in 2013.
However, the requirement that revenue collections exceed the
original revenue targets was to be construed in light of the purpose for which
the unprogrammed funds were incorporated in the GAAs as stap.dby
appropriations to support additional expenditures for certain priority ~ APs
should the revenue collections exceed the resource targets assumed 1p tl1e
bud,,et. b or when additional foreign project loan proceeds were realized.', The
254 752 Phil. 716 (2014) [Per J. Bersamin, En Banc].
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