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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.