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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. 73 / 121
Decision 73 G.R. Nos. 271059, 271347, E-02472 and
• E-04036
• i
Finally, it is significant to point out that within the 2024 and 2025
GA.As' Unprogrammed Appropriations is an item/purpose for "Strengthenirl.g
Assistance for Government Infrastructure and Social Programs" (SAGIP) in· ··,
the lump sum mnount of PHP 225.4 billion318 and PHP 160.1 billion*9
respectively. SAGIP took up 30.8% and 30.1 % of the 2024 and 2025
Unprogrammed Appropriations.
I
The 2026 NEP also contained an unprogrmnmed appropnat10n for·
SAGIP for PHP 80.86 billion, but this was removed by Congress in the 2026
GM. • •
A closer look at the SAROs issued in 2024 and 2025 for SAG IP reve~ls
that it actually covers funding requirements for multiple unrelated purpos~s, •
namely:
a. implementation of Philippine Statistics Authority's census
monitoring system, ,'
b. operation of DPWH's weighbridge station. and floating equipmentI
as well as implementation of various DPWH priority projects,
c. DSWD's assistance to individuals in crisis situations,
d .. implementation of food stamp,
e. financial assistm1ce to rice farmers,
f. implementation of projects for the President's 8 point socib-
economic agenda,
g. disaster-related infrastructure projects,
h. implementation of the Bureau of Treasury's international exhibition •
center, I
1. emergency benefits and allowances of healthcare and non-
healthcare workers,
J. Pantawid Pamilyang Pilipino Program (4Ps),
k:. establishment of regional prison facilities,
. I. assistance to disaster-affected families, ..
m. support to priority projects of recipient LG Us.
SAG IP is similarly unconstitutional because it is a prohibited lump sum.
appropriation, as defined in Belgica v Ochoa. It provides a singular lump sui\n
amount as a source of funding for multiple purposes.
More importantly, SAGIP is unconstitutional because it gives t'.1e
Executive the discretion to identify the specific projects that will be funded,
and the actual amount to be expended on each project in violation of tje /
318 Increased by PHP 175.3 billion from the PHP 50 billion proposed in the2024 NEP.
319 Increased by PHP 81.7 billion from the PHP 78.4 billion proposed in the 2025 NEP.
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