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 66 G.R. Nos. 271059, 271347, E-02472 and E-04036 kind of lump[ !sum/post-enactment legislative identification budgeting system fosters the creation of a "budget within a budget" which subverts the prescribed procedure of presentment and consequently impairs the President's power of item veto. As petitioners aptly point out, the above- described system forces the President to decide between (a) accepting the entire P[HP] 24. 79 [b Ji Ilion PDAF allocation without knowing the specific projects of the legislators, which may or may not be consistent with his national agenda and (b) rejecting the whole PDAF to the detriment of all other legislators with legitimate projects. Moreover, even without its post-enactment legislative identification feature, the 2013 PDAF Article would remain constitutionally flawed since it would then operate as a prohibited form of lump-sum appropriation as above-characterized. In particular, the lump-sum amount of P[HP] 24. 79 [b ]illion would be treated as a mere funding source allotted for multiple • •purposes of spending, i.e., scholarships, medkal 'missions, assistance to indigents, preservation of historical materials, construction of roads, flood control, etc. This setup connotes that the appropriation Jaw leaves the actual amounts and purposes of the appropriation for further determination and, therefore, does not readily indicate a discernible item which may be subject to the President's power of item veto. In fact, on the accountability side, the same lump-sum budgeting scheme has, as the CoA Chairperson relays, "limited state auditors from obtaining relevant data and information that would aid in more stringently auditing the utilization of said Funds." Accordingly, she recommends the adoption of a "line by line budget or amount per proposed program, activity or project, and per implementing agency."304 Under the Constitution, the sole power to authorize the budget lies in Congress as a legislative body. No money can be spent except in pursuance of an appropriation made by law. Appropriation means setting aside a specific amount of money for a specific purpose.305 The Special Provisions of Chapter XLIII, Unprogramm.ed Appropriations of the 2026 GAA states: Special Provision(s) I. Availment of the Unprograrnrned Appropriations. The amounts authorized herein for Purpose Nos. 2--4, 6, and 9-10 may be used when any of the following exists: a) Excess revenue collections in any one of the identified non-tax revenue sources from its corresponding revenue collection target, as reflected in the BESF; b) New revenue collections or those arising from new tax or non- tax sources which are not pmi of, nor included in, the original revenue sources reflected in the BESF; or c) Approved loans for foreign-assisted projects. 04 ' Id. at 552-555. :ms Id. at 618.