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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. 83 / 121
Decision 83 G.R. Nos. 271059, 271347, E-02472 and
E-040'.?6I
is touted as the very foundation of its institutional strength and
underpins "all other legislative decisions and regulating the balance of
influence between the legislative and executive branches of
government." Such enom1ous power encompasses the capacity to generate
money for the Government, to appropriate public funds, and to spend the
money. Pertinently, when it exercises its power of the purse, Congress
wields control by specifying the PAPs for which public money should be
spent.
It is the President who proposes the budget but it is Congress that
has the final say on matters of appropriations. For this purpose,
' 'appropriation involves two governing principles, namely: (1) "a Principle of ·
the Public Fisc, asserting that all monies received from whatever source by
any part of the government are public funds;" and (2) "a Principle of
Appropriations Control, prohibiting expenditure of any public money without
legislative authorization." To conform with the governing principles, the
Executive cannot circumvent the prohibition by Congress of an expenditure
for a PAP by resorting to either public or private funds. Nor could the·
Executive transfer appropriated funds resulting in an increase in the budget
for one PAP, for by so doing the appropriation for another PAP is necessarily
decreased. The terms of both appropriations will thereby be violated.363
(Emphasis supplied)
Nonetheless, Congress's discretion is limited by the budget ceili~g
imposed under Article VI, Section 25(1). Consequently, any increase in
unprogrammed appropriations must be accompanied by a corresponditlg
decrease in programmed appropriations. Similarly, there can be no transfer
of P APs from programmed to unprogrammed appropriations ,,withqut :! .:;t
corresponding reduction in the budget for progra~med appropriations.
In the 2024 GAA, the increase in Unprogrammed Appropriatiotis
reached its peak at PHP 449.5 billion. The total Unprogramm~d
Appropriations in the GAA amounted to PHP 731.4 billion, compared with
those proposed in the NEP at PHP 281.9 billion. The increase was brougpt
about by the following movements:
First 43 new line items were added with a total of PHP 303.1 billion.:I .. . '
Some of those items were from Programmed Appropriations. Those new
items with the biggest amounts include:
1. Priority Social Programs for Health (including the Health Facilitifs
Enhancement Program), Social Welfare and Development, High~r
Education and Technical Vocational Education (PHP 59'billion)' ,
2. Payment of Personnel Benefits (PHP 59 billion)
• '3. Government Counterpart of Foreign-Assisted Projects (PHP 5h5
billion)
4. Pension and Gratuity Fund (PHP 40.25 billion) . ':,. /...
5. Revised AFP Modernization Program (PHP 10 billion) /{
363 Arau/lo v. Aquino !I!, 737 Phil. 457, 601-603 (2014) [Per J. Bersamin, En Banc].
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