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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. 77 / 121
Decision 77 G.R. Nos. 271059, 271347, E-02472 ahd. E-04036. I Respondents further add that Congress did not violate the expenditure ceiling requirement underthe Constitution.344 Unprogrammed appropriatiohs are not part of the National Government Expenditures in the BESF becauke • they do not have definite-merely contingent-sources offunding.345 Since Congress did not increase the total budget proposed by the president in ~e BESF, it did not violate the Constitution.346 i I ! Congress acted ~ith grave abuse of discretion when it increased tlte Unprogrammed Appropriations recommended by the Executive Braneh' in the 2024 GAA by PHP 449.5 billion. I (i) The prohibition against increase under Article VI, Section 2scb explicitly refers to appropriations recommended by the president for tJ,ze operation of the government, as specified in the budget of expenditures a/2d sources of financing. The provision does not distinguish nor qualify "appropriations," so it reasonably covers both programmed ariid unprogrammed appropriations. ' I There is only one budget submitted to Congress, which becomes tie · basis of the general appropriations bill.347 The budget incorporates in ote document the gover'mnent's fiscal policies, including tax, expenditure 3fdI debt matters. The objective is to provide a clear and. comprehensive presentation of the needs of the goverrunent and its financial condition.~48 Book VI, Chapter 3, Section 12 of the Administrative Code prescribes ~e . form and content of the budget: ' SECTION 12. Form and Content of the Budget. - The budget proposal of the President shall include current operating expenditures and capital outlays. It shall comprise such funds as may be necessary for the · operation of the programs, projects and activities of the various departments and agencies. The proposed General Appropriations Act and other Appropriations Acts necessary to cover the budget proposals shall be submitted to the Congress to accompany the President's budget submission. The budget shall be presented to the Congress in such form.:and content as may be approved by the President and may include the following: (1) A bµdget message setting forth in .brief the government's budgetary thrusts for the budget year, including their impact on development goals, monetary and fiscal objectives, and 344 Id. at 33. 345 Id at 37. 346 Id. 347 CONST., art. VII, Sec. 22. ]48 ADMINISTRATIVE CODE, Book VI, Chapter 4, sec. 27; Chapter 3, sec. 12.