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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. 88 / 121
Decision 88 G.R. Nos. 271059, 271347, E-02472 ai(ld
E-04036i
First, Programmed Appropriations transferred to Unprogrammdd
Appropriations to create fiscal space within the programmed appropriations
for projects of legislators; :
• Second, transparency and •accountability in public· spending. may Tue ..
greatly diminished. The lack of specificity in Unprogrammed Appropriatiotis
items, such as Support to FAP and SAGIP, makes them inherently moie
difficult for the public and even legislators to scrutinize and track how tfue
1
funds are eventually utilized;
Third, some priority projects end up being partially or fully defunde~,
which may impede the Government's achievement of its economic
development goals; I'
I
I ...
Lastly, Unprogrammed Appropriations may include funding for regular
agency operations, personnel benefits, and other recurring expenses-'-
foreseeable operational costs that would be more appropriately included in the
Programmed Appropriations. :
I
, .Unprogrammed Appropriations has morphed from.a narrow standby
authority, contingent on the availability of additional revenues, into a basin
for projects and programs deprioritized by Congress. It has become!' a
mechanism through which Congress may effectively alter the budget
constitutionally mandated to be formulated by the Executive. '
Crucial to fiscal prudence is the proper allocation of resources, and t~is
must be evident in the Budget. •
Congress severely distorted the Budget by defunding strategic ••
development programs and projects that formed part of the original proposal
under the Programmed Appropriations. In doing so, it created an "artificial"
fiscal space that paved the way for increases in other items in the Budg~t.
These included the DPWH's programs, through SIP AG and BIP, which.
received the highest increase of PHP 175.7 billion, as well as programs un~er
the DOH DSWD and DOLE that were directed toward legislators' patronage ' ' ''projects, such as AK.AP and TUPAD. • •
The defunded strategic development programs and projects under ttie .
Programmed Appropriations were transferred to Unprogrammed
Appropriations, resulting in an excessive level of standby appropriations.
'
Congress's actions, undertaken without transparency, distorted theI /
integrity of the Budget and undermined the tedious budget preparation •
process.
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