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 89 G.R. Nos. 271059, 271347, E-02472 add ' 6 E-0401 When Unprogrammed Appropriations are expanded beyond fiscal limits and treated as readily activatable, they risk becoming not merely ia • • ' source of contingent spending authority, but a mechanism for circumventir{g constitutional restraints. (iv) Parenthetically, Section 24, Chapter IV, Book VI of the Administrati'(e Code of 1987 explicitly prohibits increasing the appropriation for any project or program beyond the amount submitted by. the president. in the budg~t proposal: • SECTION 24. Prohibition Against the Increase of Appropriation. - The Congress shall in no case increase the appropriation of any project or program of any department, bureau, agency or office of the Government over the amount submitted by the President in his budget proposal. In case of any reduction in the proposed appropriation for a project or program, a corresponding reduction shall be made in the total appropriation of the department, office or agency concerned and in the total of the General Appropriations Bill. Hence, the PHP 449.5 billion increase in Unprogramm~d Appropriations under the 2024 GAA likewise violates Book VI, Chapter fl-, Section 24 of the Administrative Code of 1987. ., VI (A) • ' ! I Petitioners Filipinos for Peace maintain that SAGFs are beyond 14e scope of the GAA as they are non-discretionary obligations mandated QY enabling statutes.367 They argue that, by increasing the appropriations f9r SAGFs, the 2025 GAA effectively amended their enabling laws, which cann~t • be done through the GAA, as substantive laws cannot be amended by 4n appropriations law.368 • I Respondents, on the other hand, assert that the inclusion of automat~o • • appropriations in the BESF was not intended to create new appropriations, 1s SAGFs are already appropriated under existing substantive laws. Rather, th~y are included to present a comprehensive fiscal picture of government ca$h flows and expenditures. They further contend that adjustments to SAGfs cannot be considered an increase in the President's recommend~d appropriations, as releases ofSAGFs are contingent on actual collections :frofll specific revenue sources.369 'J67 Auo-ust 3 2026 Memorandum filed by Petitioner Filipinos for Peace, Justice & Progress Movement I~c., b ' • . I 1 pars. 4.36 to 4.43. 368 Id. pars. 4.44-4.47. " 9 August 3, 2026 Memorandum filed by the Office of the Solicitor General, pp. 132-135