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 81 G.R. Nos, 271059,271347, E-02472 kind E-04?36 of revenues and expenditures and on a coherent fiscal plan based on actual 1economic realities. _ The Court h_as ?reviously cautioned again~t releasing u~program1ed funds based on artificial revenue surpluses, as this could constitute unsound fiscal management that disregards the budget plan and fosters unnecessirrY ' budget deficits.357 Budget deficits should be kept within limits, as excess(ve deficits threaten macroeconomic stability.358 i i Unprogrammed appropriations, which were historically maintained at moderate amounts consistent with their nature as standby authorizations, h;).ve shown a steep increase over the past four years. ' •From 1989 to 2010, Unprogrammed Appropriations remained belbw PHP 100 billion, except in 2008 (PHP 114.5 billion) and 2010 (PHP llii.9 billion). ! I From 2011 to 2018, Un programmed Appropriations generally ranged from PHP 64 billion to PHP 140 billion. The ratio of apprm(ed Unprogrammed Appropriations to total new appropriations ranged from 2.9% in2018to 12.3%in2012. I The levels of Unprogrammed Appropriations continued to rise, frbm PHP 187.1 billion in 2019 to a peak of PHP 807.2 billion in 2023, before slightly declining to PHP 731.4 billion in 2024. The ratio of appro'{ed Unprogrammed Appropriations to total new appropriations was 18% in 21)23 and 15.4% in 2024. ! , . From 2000 ,to. 202q, Congress . appro,ved UnprogrammedI Appropriations more than the amounts proposed by the president only eight times: 2000, 2004, 2008, 2010, 2022, 2023, 2024, and 2025. The increases in the last four years were particularly large: PHP 100 billion in 2022, PHP ~19 billion in 2023, PHP 449.5 billion in 2024, and PHP 373 billion in 2025. _I i The releases under Unprogrammed Appropriations for Fiscal Years 2024 and 2025 are shown in the table below: 357 Arau/lo v. Aquino!!!, 752 Phil. 716 (2015) [Per J. Bersamin, En Banc]. _ _ ;:J 358 TSN, April 7, 2026 Oral Arguments, pp. 84-89 (Interpellation between SAJ Leonen and Am1cus Curiae / Solita Monsod); Philippine Development Plan 2023-2028, pp. 251-261; Department of Budgetjand Manaoement Medium-Term Fiscal Framework Midtenn Update, 2022-2030; Department of Budget and Manage1~ent, Review of the Medium-Term Macroeconomic Assumptions and Fis~~l :rogra~ f?r Fiscal Years (F.Y.) 2025 to 2028 June 26, 2025, available : at • https://www.dbm.gov .ph/index. php/management-2/3466-191 st-dbcc-joint-statement-on-the-revie"\-of- the-med ium-tenn-macroeconom ic-assum_ption.~-and:-fiscal-pr9gra.m-fo_r-_fisca)-years-fy-2025-to-2018 (11~t accessed on October 6, 2026).