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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. 70 / 121
Decision 70 G.R. Nos. 271059, 271347, E-02472 and
E-04036
expenditure for certain specific purposes, aids and donations for carrying
out certain activities, or deposits made to cover to cost of special services to
, be rendered to priv<'!te parties. Unless otherwise expressly provided by law,
• when any Board, head of department, chief of bureau or office, or any other
ofiicial, is authorized to appropriate, allot, distribute or spend any lump-sum
appropriation or special, bond, trust, and other funds, such authority shall
be subject to the provisions of this section.
Second, considering the contingent nature of unprogrammed
appropriations and given the country's deficit situation, additional revenues.
when they arise are rarely sufficient to fund all purposes under the •
Unprogrammed Appropriations. Without sufficient standards, Special
Provisions (I )(a) and (b) also give the president the discretion to choose which
among the purposes under Unprogrammed Appropriations will be funded,
which will not, and what amounts will be spent. Concomitantly, it gives the .
president the power to release or withhold funds. These are allocative
judgments which occur during budget execution; hence, unconstitutional.
The 2026 GAA lists down the expenditures/purposes under the
Unprbgrammed Appropriations as follows: •
Personnel Maintenance Capital Outlays Total
Services and Other
Operating
Expenses
PURPOSE(S)
! .Budgetary Support 6,895,000,000 6,895,000,000
to Government
Owned and/or
Controlled
Corporations
2. Suppmi to Foreign- 34,238,418,000 63,067,253,000 97,305,671,000
Assisted Projects
3. Government of the 5,530,700,000 30,238,781,000 35,769,481,000
Philippines
Coun\erpart of . . .
Foreign Assisted
Projects
4. Program on Risk 3,600,000,000 3,600,000,000
Management
5. Prior Years' LGU 14,623,000 14,623,000 •
Shares
6. Revised AFP 50,000,000,000 50,000,000,000
Modernization
Program
7. Fiscal Support 4,320,765,000 4,320,765,000
Anearages for
Comprehensive
Automotive
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