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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. 62 / 121
Decision 62 G.R. Nos. 271059, 271347, E-02472 and
E-64036
bills shall originate exclusively in the House of Representatives, but the
Senate may propose or concur with amendments.
SECTION 25. (1) The Congress may not increase the appropriations
recommended by the President for the operation of the Government as
specified in the budget. The form, content, and manner of preparation of
the budget shall be prescribed by law.
(2) No provision or enactment shall be einbraced in the general
appropriations bill unless it relates specifically to some particular
appropriation therein. Any such provision or enactment shall be limited in
its operation to the appropriation to which it relates[.]
Article VII
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 receipts from existing and proposed revenue
measures."
In Guingona, Jr., the constitutionality of the automatic appropriation
for debt servicing in the 1990 budget-as authorized by Presidential Decree
No. 81,291 Section 31 of Presidential Decree No. 1 I 77,292 and Presidential
'Decree No. 1967293-is questioned on the ground, among others, that the laws.
2'.) 1 Presidential Decree No. 81 (1972), sec. 7 states:
SECTION 7. Section six of the same Act is hereby further amended to read as follows:
"SEC. 6. Any provision of law to the contrary notwithstanding, and in order to enable the Republic of
the Philippines to pay the principal, interest1 taxes and other normal banking charges on the loans,
credits or indebtedness, or on the bonds, debentures, securities or other evidences of indebtedness sO!d
in international markets incurred under the authority of this Act, the proceeds of which are deemed
appropriated for the projects, all the revenue realized from the projects financed by such loans,
credits or indebtedness, or on the bonds, debentures, securities of other evidences of indebtedness,
shall be turned over in full, after deducting actual and necessary expenses for the operation and
maintenance of said projects, to the National Treasury by the government office, agency or
instrumentality, or government-owned or controlled corporation concerned, which is hereby
appropriated for the purpose as and when they shall become due. In case the revenue realized is •
insufficient to cover the principal, interest and other charges, such portion of the budgetary savings as
may be necessary to cover the balance or deficiency shall be set aside exclusively for the purpose by!the
government office, agency or instrumentality, or government-owned or controlled corporation
concerned: Provided, That, if there still remains a deficiency, such amount necessary to cover the
payment of the principal and interest on such loans, credit or indebtedness as and when they shall
become due is hereby appropriated out of any funds in the National Treasury not othen¥ise
appropriated: I'rovided,fitrther, That the Monetary Board shall make provisions out of current foreign
ex'c'hange receipts for the foreign exchange requirements to 'service the extem·aI •debt: And provided,
finally, That this requirement to turnover the net revenues shall not apply in relending arrangements
covered under Section I (BJ and (C)." (Emphasis supplied)
292 Presidential Decree No. 1177 (1977), sec. 31, Budget Reform Decree of 1977 states:
SECTION 31. Automat;c Appropr;ations. - All expenditures for (a) personnel retirement premiums,
government service insurance, and other similar fixed expenditures, (b) principal and interest on public
debt, (c) national government guarantees of obligations which are drawn upon, are automatically ...
appropriated: provided, that no obligations shall be incmred or payments made from funds tlius
automatically appropriated except as issued in the fonn of regular budgetary allotments.
293 Presidential Decree No. 1967 (1985), sec. l, Strengthening the Guarantee and Payment Positions of the
Republic of the Philippines on Its Contingent Liabilities states: /
SECTION I. There is hereby.appropriated, out of any funds in the National Treasury not othef\3/ise
appropriated, such amounts as may be necessary to effect payments on foreign or domestic loans, or
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