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 6 G.R. Nos. 271059, 271347, E-02472 and E-04036 authorization to incur obligations in addition to the original expenditure program. This authorization may be used if the resource target corresponding to such expenditure program is exceeded in the course of budget execution." 10 It was in the 1989 GAA where Unprogrammed Funds 11 was reflected as a separate item. About one-third of the unprogrammed funds was for various foreign-assisted projects, funding for which was still under negotiation. 12 Amicus curiae Dr. Benjamin Diokno explains that "by design, unprogrammed appropriations serve as standby authorization ... especially for foreign-assisted projects that were not included in the proposed budget," 13 because of rigorous evaluation, but likely to be effective during the forthcoming fiscal year. 14 Unprogrammed appropriations are also driven by the likelihood that actual revenues will exceed projections in the Budget of Expenditures and Sources of Financing (BESF). 15 In the 1990 GAA, it was explicitly provided that unprogramined funds· "may be released when the corresponding funding or receipts for the pu1pose have been realized. "16 The 1991 GAA added a condition for release of unprogrammed funds-"when the revenue collections exceed revenue targets submitted by the President to Congress." It was also provided that "no amount of the unprogrammed fund shall be funded out of· the saving's generated from programmed items." Subsequent GAAs further elaborated on release conditions and repo1torial safeguards through the Special Provisions of the Unprogrammed Appropriations. Beginning 2003, collections from new sources (or those not considered in the original revenue targets) may additionally be used to cover releases from appropriations in the unprogrammed fund. Later, in 2015, the use and availment of the unprogrammed appropriations were conditioned upon the occurrence of any of the following events: 10 1987 Budget of Receipts and Expenditures, p. 255, available at https://www.dbm.gov.ph/index.php/ budget-documents-archives?view=atiicle&id=2446&catid=308 (last accessed on July 29, 2026). 11 History, Concept and Purpose of UAs, OGC's Subsequent Compliance dated March 16, 2026. From 1989 until 2014, Unprogrammed Appropriations was refe1Ted to as Un programmed Funds. 11 The J 989 BESF defines Un programmed Appropriations as standing authority to incur additional agency obligations for priority programs or projects when revenue collections exceed the targets, additional grants or foreign funds are generated, and when unforeseen expenditures arise during the budget year. In the I 991 BESF, the condition "when unforeseen expenditures arise during the budget year" was removed. 13 TSN April 7, 2026, p. 40. Amicus Curiae Hon. Benjamin E. Diokno. 14 Id. at40-41. l:i Id 16 \ 990 GAA, sec. XLV, Un programmed Fund, Special Provisions (I).