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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. 69 / 121
Decision 69 G.R. Nos. 271059, 271347, E-02472 and
E-04()36
availability of funding for programmed P APs if projected revenues are not
realized. 3 10 •
A separate opinion in Araullo expounds on the probability of projected
revenues not being realized during the fiscal year:
Congress appropriates based on projected revenues for the fiscal
year. Not all revenues are available at the beginning of the year. The budget
is planned, and the [GAA] is enacted, before the actual generation and
collection of government funds. Revenue collection happens all throughout
the year. Taxes and fees, for instance, still need to be generated.
The appropriations act is promulgated, therefore, on the basis of
• 'hypothetical revenues of government in the , coming fiscal year. While
hypothetical, it is the best educated, economic, and political collective guess
of the President and Congress.
Projected expenditures may not be equal to what will actually be
collected. Hence, there is no prohibition from enacting budgets that may
result in a deficit spending. There is no requirement in the Constitution .that
Congress pass only balanced budgets.
Ever since John Maynard Keynes introduced his theories of
macroeconomic accounts, governments have accepted that a certain degree
of deficit spending (more expenditures than income) is acceptable to
achieve economic growth that will also meet the needs of an increasing
population.311 (Citations omitted)
Parenthetically, under paragraph S(b) of the Special Provisions, the
DBM secretary is authorized not only to approve the use of unprogrammed
appropriations but to also use the allotment under one purpose, except the
Budgetary Support to GOCCs and Support to FAPs; to cover the deficiency
in any other purpose. In fact, only the DBM is involved in the SARO issuance
process.312 This goes against Book VI, Chapter 4, Section 35 of the
Administrative Code, which requires special budget requests to be approved
by the president:
SECTION 35. Special Budgets for Lump-Sum Appropriations. -
Expenditures from lump-sum appropriations authorized for any purpose or
for any department, office or agency in any annual General Appropriations
Act or other Act and from any fund of the National Government, shall be
made in accordance with a special budget to be approved by the
President, which sha]] include but shall not be limited to the number of each
kind of position, the designations, and the annual salary proposed for which
an appropriation is intended. This provision shall be applicable to all
revolving funds, receipts which are automatically made available for
310 ADMINISTRATIVE CODE, Book VI, Chapter 5, sec. 33 recognizes the authority of the DBM secretary,
with the approval of the President, to reduce allotments of appropriations in case he/she finds that .the
prnbable receipts from taxes OP other sources of any fund wiH be· less than anticipated. . . ··. . .
311 J. Leonen, Concuming Opinion in Araullo v. Aquino Ill, 737Phil. 457, 758 (2014) [Per J. Bersamin, En
Banc].
312 OSG Compliance dated April 17, 2026, Annex K.
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