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

Decision 80 G.R. Nos. 271059, 271347, E-02472 and E-04036I not provide or prescribe any particular form of words or religious recitals in which an authorization or appropriation by Congress shall be made, except that it be 'made by law,"' an appropriation law may-according to Philconsa-be "detailed and as broad as Congress wants it to be" for as long as the intent to appropriate may be gleaned from the same . . . . To reiterate, if a legal provision designates a determinate or determinable amount of money and allocates the same for a particular public purpose, then the legislative intent to appropriate becomes apparent and, hence, already sufficient to satisfy the requirement of an "appropriation made by law" under contemplation of the Constitution.355 The argument that unprogrammed appropriations are not covered by the limitation because it is subject to "trigger conditions" is untenabje, because it is still a "legislative authorization directing payment out_ bL government funds under specified conditions or for specified purposes."~56 This budgetary tool enables the Executive Department to spend for obligations under the unprogrammed appropriations as the need arises without having to go back to Congress to enact a separate law appropriating funi:!s therefor. The unprogrammed appropriation becomes an essential componeht of the national expenditures upon the occurrence of any of the trigger conditions. Thus, the appropriations recommended by the President as specified in the budget of expenditures and sources offinancing under Article VI, Section 25(1) means the total of the progra,;,med appropriations a11d unprogrammed appropriations submitted by the President in his budget proposal. •I Applying in this case, Congress increased the Unprogra.mmed • Appropriations from PHP 281 billion to PHP 731.4 billion, while the level bf Programmed Appropriations remained the same at PHP 4,019.8 billion; thus, effectively increasing the President's proposed appropriations by PHP 44l5 billion. Consequently, Congress' increase of the Unprogrammed Appropriations by PHP 449.5 billion violated the constitution)il prohibition under Article VI, Section 25(1). (ii) The purpose of Article VI, Section 25(1) of the Constitution, whi6h prohibits Congress frotn increasing the appropriations recommended by ~he president, is to maintain fiscal discipline and prevent excessive public expenditures that could balloon the budget deficit. This constitutional limit requires that the national budget be anchored on the Executive's projecti~ns / 355 Id. at 564-565. 356 ADM!NISTRATIVE CODE, Book VI, Chapter I, sec. 2. Definition of'"appropriations."