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 90 G.R. Nos. 271059, 271347, E-02472 and E-04036I Article VI, Section 29 of the Constitution recognizes two classifications of appropriation measures: general and special appropriations. Section 129 reads: SECTION 29. (I) No money shall be paid out of the Treasury except in pursuance of an appropriation made by law. (2) No public money or property shall be appropriated, applied, paid, or employed, directly or indirectly, for the use, benefit, or support of any sect, church, denomination, sectarian institution, or system of religion, or of any priest, preacher, minister, or other religious teacher, or dignitary as such, except when such priest, preacher, minister, or dignitary is assigned to the armed forces, or to any penal institution, or government orphanage or leprosarium. (3) All money collected on any tax levied/or a special purpose shall be treated as a special fund and paid out fiJr such purpose only. If the purpose for which a special fund was created has been falfilled or abandoned, the balance, if any, shall be tran~ferred to the general funds of the Government. (Emphasis supplied) A general appropriation law "is one passed annually to provide for.the·. financial operations of the entire government during one fiscal period,"r70 while a special appropriation is enacted for a specific purpose. Revenues collected pursuant to such special purpose are treated as a special fund to be used solely for that purpose. This serves as a safeguard against the misuse1of special funds. 371 ' The Department of Budget and Management defined "earmarking" !as "the government practice of setting aside tax proceeds for specific purpo~es to ensure funding for critical programs and projects."372 • ! Earmarked revenues may be classified as either "Use of Income in tpe General Fund" or "Special Accounts in the General Fund."373 The differe~ce between the two is crucial, as it determines how the earmarked revenues are released to implementing agencies.374 • ' •37° Confederation of Coconut Farmers Organizations c~f"the Philippines, Inc., v. Aquino Ill, 815 Phil. 1q36, I 053 (2017) [Per J. Mendoza, En Banc]. 371 Id. 1 372 Technical Notes on the 2025 Proposed National Budget, Department of Budget and Management, p.:45, available at https://www.dbm.gov.ph/images/pdffiles/2025-Technical-Notes.pdf (last accessed on October 6, 2026). 31:, Id. 37•1 Anthony Arvin V. Salazar, Ways Forward in Managing Earmarked ~evenues ~n the Philippines: Ti'e~ds, • Issues, and Policy Options, House of Representatives - Congressional Policy and Budget Rese~rch Department, Issue No. 4 (2026), pp. 3-4.