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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. 67 / 121
Decision 67 G.R. Nos. 271059, 271347, E-02472 and E-04036 Release of funds shall be subject to the submission of a Sp~cial Budget Request, and other relevant budgetary requirements in accordance •with applicable laws, rules, and regulations and the following: (i) for excess · revenue collections, issuance of a certification that remitted collections to the BTr from a particular revenue source has exceeded the corresponding revenue collections target; or (ii) for new revenue collections, issuance of a certification that remitted collections identified, were not part of, nor included in, the original revenue collection targets reflected. In the case of approved loans for foreign-assisted projects, the loan proceeds shall be promptly released to the agency concerned, through the issuance of corresponding SARO upon submission of a Special Budget Request, supported by a copy of the perfected loan agreement, as approved in accordance with pertinent laws, rules, regulations, and guidelines issued thereon. In view of the nature of the sources of funding for Un programmed Appropriations, the validity period of releases covering Unprogrammed Appropriations shall be until December 31, 2026, while obligations and . disbursements therefrom shall be subject to the. 1:ule. under Section 77 of the General Provisions of this Act. 8. Amounts under the Unprogrammed Appropriations. The DBM is hereby authorized to approve the following: a. Use of appropriations within the authorized purposes; and b. Use of appropriations under the Purposes of the Unprogrammed Appropriations, except by the Budgetary Support to GOCCs and the Support to Foreign-Assisted Projects, to cover deficiencies in the amounts authorized in any of the purposes under the Unprogrammed Appropriations. The DBM shall post on its website the status of monthly releases charged against the Unprogrammed Appropriations. c. Reportorial Requirement. The DBM shall submit to the Speaker of the House of Representatives, the President of the Senate of the Philippines, the House Committee on Appropriations, and the Senate Committee on Finance, either in printed form or by way of electronic document, quarterly reports on releases from the Unprogrammed Appropriations. From the above Special Provisions, paragraph states that unprogrammed appropriations may be used when any of the following instances exist: (i) excess revenues from any one of the non-tax sources stated in the BESF; (ii) new revenues; or (iii) approved loans for foreign-assisted projects. In addition to violating Article VII, Section 22 as previously discussed, the Court finds Special Provisions l(a) and (b) to be too broad and lackingadequate guidelines or limitations to map out the boundaries of the president's /