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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. 8 / 121
Decision 8 G.R. Nos. 271059, 271347, E-02472 and
E-04036
source has exceeded the corresponding revenue collections target; or (ii) for
new revenue collections, issuance of a certification that remitted collections
identified were not part of, nor included in, the original revenue collection
targets reflected.
In the case of approved loans for foreign-assisted projects, the
issuance of SARO covering the loan proceeds shall be subject to submission
by the agency concerned of a Special Budget, together with the physical and
financial plan, project profile, and a copy of the perfected loan agreement,
as approved in accordance with pertinent laws, rules, regulations, and
guidelines issued thereon.
Nevertheless, prioritization of funding of the purposes under tlie •
unprogrammed appropriations may be as follows, presented from top
priority:
a) Not requiring excess/new revenue collections:
(i) Support to foreign-assisted projects; and
(ii) Budgetary support to GOCCs;
b) Requiring excess/new revenue collections:
(i) Personnel benefits;
(ii) Social services/ continuing public health emergency;
(iii) GOP counterpart of foreign-assisted projects;
(iv) Infrastructure projects; and
(v) Other priority projects authorized within purpose nos. I, 3-5,
and 7-5 I.
Notwithstanding the foregoing, the order of pnonty may be
modified to support the funding of urgent or implementation-ready projects
which are: (I) based on commitments to international/multilateral
organizations; or (2) in furtherance of (i) the Philippine Development Plan
2023-2028, (ii) the Medium-Term Fiscal Framework, (iii) the 8-Point
Socioeconomic Agenda, and (iv) those that may be identified as key budget
priorities.
In view of the nature of the sources of funding for Unprogrammed
Appropriations, the validity period of releases covering Unprogrammed
Appropriations shall be until December 31, 2024, while obligations and
disbursements therefrom shall be subject to the rule under Section 70 of the
General Provisions in this Act. 17
In the 2025 GAA, the additional funding sources were removed, but the
prioritization of funding was retained. The 2026 GAA contained a similar
provision for the availment of unprogrammed appropriations.
For almost three decades, or from 1989 to 2018, the Unprogrammed
Appropriations were to fund six to no more than 12 purposes, including
"Budgetary Support to [GOCCs]," "Support for Foreign-Assisted Projects
(FAPs)," and "General Fund Adjustments." In 2007, "Support to
Infrastructure Projects and Social Programs (SIPSP)" was added under the . /
Unprogrammed Appropriations, until it was replaced in 2024 by i:he /
17 2024 GAA, Chapter XLIII, Unprogrammed Appropriations, Special Provision (I).
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