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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. 74 / 121
Decision 74 G.R. Nos. 271059, 271347, E-02472 and
E-04036
principle of non-delegation of legislative powers. Pursuant to Belgica v.
Ochoa, as these intermediate appropriations are made by the Executive only _
after the GAA is passed and, hence, outside of the law, it necessarily meaµs
that the actual items of the SAGIP appropriation would not have been writt~n
into the General Appropriations Bill. This "post-enactment identification
feature" subverts the procedure prescribed under the Constitution. '
The actual releases of SA GIP in F.Y. 2024320 and 2025321 amounted to
PHP ••200.029 billion (37.6% • of total releaies from Unprogrammbd
Appropriations) and PHP 51.969 billion (23.8%). !
In F.Y. 2024, DPWH alone received PHP 155.9 billion from SAGIP-'
29.3% of all unprogrammed releases and 77.9% of total SAGIP.322 I•
Five allotment releases323 with an aggregate of PHP 146.4 billion were
to fund "various priority projects which are essential for achieving the .
"" OSG Comnliance dated April 17 2026 , Annex B shows·
Program Amount % of total releases
SAGIP PHP 200.08 37.6%
Support to FAPs PHP 127.IB 23.9%
Personnel Benefits PHP 56.9B 10.7%
Gov't Counterpart-FAPs PHP 40.9B 7.7%
Public Health Emerg. PHP 27.5B 5.2%
Priority Social Health • Pl-iP l9.2B 3:6¾
AFP Modernization PHP IQ.OB 1.9%
BSGCs Pl-IP 10.2B 1.9%
Pension & Gratuity PHP 8.7B 1.6%
Others PHP 31.1 B 5.8%
TOTAL Pl-IP 531.48 100%
rn OSG Co rnrnl"anceI dated Aoril 17 , 2026 , Annex E shows·
Program Amount % of tota.l releases
Support to FAPs PHP 110.4B 50.6%
SAGIP PHP 52.08 23.8%
Payment of Personnel Pl-IP 20.4B 9.4%
AFP Modernization PHP 15.7B 7.2%
Government Counterpart-F APs PHP 10.5B 4.8%
BSGCs PHP 6.3B 2.9%
Risk Management PHP I.OB 0.5%
Nampeidai Refund PHP0.2B 0.1%
Others PHP 1.8B 0.8%
TOTAL PHP 218.28 100°/4,
122 DPWH SAG IP releases were made in the last quarter.
m O SG Comoliance d ate d A,on·117 2026 A nnex B s h ows:
Nov. 11, 2024 SARO-BMB-A-24-0017624 PHP 12,024,184,000
Nov. 14, 2024 SAR.O-BMB-A-24-0017785 PHP 69,994,940,000
Nov. 28, 2024 SARO-BMB-A-24-0018374 PHP 3.018,250,000
Dec.3,2024 SARO-BMB-A-24-0018544 PHP 9,980.000,000
Dec. ?7,2024 SAR.O-BMB-A-24-0019575 PHP 51,341,420,000 .
TOTAL PHP 146,358,794,000
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