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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. 82 / 121
Decision 82 G.R. Nos. 271059, 271347, E-02472 ~d E-04036 i METRIC F.Y. 2024 (PHP) F.Y. 2025 (PHP) Total Disbursements 5.925 trillion359 6.082 trillion ' Budget deficit 1.506 trillion -1.562 trillion Unprogrammed 531.374 billion360 218.195 billion361 Appropriations - Allotment Releases Unprogrammed 8.97% 3.62% Appropriations as % of Total Expenditures Higher-than-planned-spending, resulting from approvbd Unprogrammed Appropriations exceeding those proposed, results in failure of government to meet its targets as shown in the table below:362 GDP Growth NG Deficit to NG debt stock to Year GDP ratio GDP ratio ' Tare:et Actual Tare:et Actual Taroet Actual I 2023 6-7% 5.5% 6.1% 6.2'1/J '60-62% 60.1% ' 2024 6.5-8% 5.7% 5.1% 5.7% 57-61% 60.7% ' 2025 6.5-8% 4.4% 4.1% 5.6% 56-59% 63.2% ' (iii) As discussed earlier, the BESF referred to in Article VII, Section 22 of the Constitution includes all appropriations, whether programmed pr unprogrammed. Thus, the prohibition against increasing appropriations under Article VI, Section 25( 1) applies to the total appropriations, both programmed_ and unprogrammed. At this instance, the Court recognizes that part of Congress' oversight powers over the budget is to determine which P APs to fund and by how muqh, as well as to make reallocations, including transfers from programmed !to unprogrammed appropriations arid vice versa Chief Justice Gesmundo poirits out that Congress remains supreme in exercising the power of the purse, consistent with its responsibility as guardian of the purse. As declared iin Araullo: Congress acts as the guardian of the public treasury in faithful discharge of its power of the purse whenever it deliberates and acts on the budget proposal submitted by the Executive. Its power of the purse ' 59 Table 8.2 of2026 BESF. ''° Annex C, OSG Compliance; Status of UAs as of December 31, 2024. 361 Annex F, OSG Compliance; Status of UAs as of December 31, 2025. ~62 Brief of Am;cus Curiae Prof. Solita Monsod's Brief, pp. 10 and 15.