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 58 G.R. Nos. 271059, 271347, E-02472 and E-04036 Persqnnel Services Requirements" in the amount of PHP 43,245,110,000, which was not present in the NEP nor the House- and Senate-approved bills.271 Petitioners Erice and De Lima also highlighted the glaring defects ;in the 2024 and 2025 GAAs as lump-sum items were included under Unprogrammed Appropriations, specifically under the Strengthening Assistance for Government Infrastructure and Social Programs.272 "By its name, the lump-sum item contains all government projects which may be_- ••••••• characterized as either infrastructure and social programs."273 Consequently, there is no level of particularity in this specific budget item. Respondents counter that the specifically assaileq . item of- Unprogrammed Appropriations in the amount of PHP 43,245,110,000 was vetoed by the president, hence it no longer presents a live controversy.274 At any rate, the annual appropriation measure originated in the House, and the subsequent amendments introduced by the Senate and the Bicameral Conference Committee formed part of the· constitutionally recognized process. Moreover, the enrolled 2026 General Appropriations Bill, signed by the speaker and Senate president and certified by the secretaries of both Houses, is conclusive not only to its provisions but also as to its due enactment.275 That Congress used Unprogrammed Appropriations to "move around" the budget from Programmed to Unprogrammed Appropriations, as suggested by pet1t10ners, is likewise not a ground to invalidate Unprogrammed Appropriations so long as the president's budgetary ceiling is not breached.276 Chapter XLIII on Unprogrammed Appropriations in· the 2026 . GAA partly constitutes an undue delegation of legislative power insofar as the first and second fiscal conditions are concerned, i.e., excess or new revenues. Under the principle of separation of powers, each of the three branches of government "has exclusive •cognizance of 1natters falling within its constitutionally allocated sphere."277 Corollary to the doctrine of separation of powers is the principle of non-delegation of powers. The basic idea behind separation of powers is to prevent tyranny and, ultimately, increase accountability. The separation of powers doctrine assumes that unchecked power tends toward tyranny. Liberty requires institutional restraints within government, assigning functions to distinct 171 Id at36---37. 272 Id. at 48. n~ Id. ""' Respondents' Comment dated March 23, 2026, p. 57. 275 Id. at 60. 210 Id. at 61. . 277 Province of Pampanga v. Executive Secretary, 893 Phil. 277 (2021) [Per J. Leonen, £,_n Bc:nc]. (Citation omitted) •