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 56 G.R. Nos. 271059, 271347, E-02472 and E-04036 Here, in the 2026 NEP, included under the proposed Unprogrammed Appropriations of PHP 249,989,309,000 is the item "Support to Foreign- Assisted Projects" in the amount of PHP 97,305,671,000. However, there is no itemization of these F APs that are anticipated to be approved in the fiscal year of 2026, thus falling short of the constitutional requirement under Article VI I, Section 22. V(B) Petitioners Erice and De Lima argue that "the structure of [Unprogrammed Appropriations] is constitutionally infirm because it authorizes appropriations without the required revenue certainty contemplated by Article VI, Section 25( 4)."261 They add that the Constitution requires that the fiscal basis be established in the appropriation itself, not supplied later through executive implementation.262 Respondents contend that Article VI, Section 25( 4) applies to special appropriations bills, not to general appropriations bills,263 . Special appropriations bills are subject to heightened fiscal safeguards since they operate outside the regular annual budget cycle and, when enacted, authorize expenditures outside the annual appropriations framework of the GAA.264 Article VI, Section 25( 4) of the Constitution is not applicable. Article VI, Section 25( 4) of the Constitution states: Section 25 ..... (4) A special appropriations bill shall specify the purpose for which it is intended, and shall be supported by funds actually available as certified by the National Treasurer, or to be raised by a corresponding revenue proposed therein. Petitioners rely on the wrong constitutional_ prov1s10n, as such 'requirement refers t~ special appropriations bills. In this case, the unprogrammed appropriations are items included in the 2026 General Appropriations Bill. Therefore, the provision is not applicable. 2"' Petition for Certiorari and Prohibition (G.R. No. E-04036), p. 34. 262 id. at 35. 263 Respondents' Comment dated March 23, 2026, p. 53. 164 Id. at 55.