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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. 91 / 121
Decision 91 G.R. Nos. 271059, 271347, E-02472 and E-04036 Revenue classified as Use of Income refers to "funds that agencies are legally authorized to utilize for purposes under their enabling laws."375 These funds are automatically appropriated and incorporated into the agenci~s' budgets during the preparation of the NEP. They become available once the GAA takes effect through the General Appropriations Act as the AllotmeµtI Order (GAAAO), which generally serves as the obligational authority.376 I On the other hand, a SAGF is "[a] fund whereby proceeds from speci:ffic revenue measures and grants earmarked by law for specific priority projetjts are recorded."377 , ! ' ! An earmarked revenue accruing to a Special Account in the Gene~al Fund is subject to a special budget to be approved by the President pursua:'nt to Book VI, Chapter 4, Section 35 of the Administrative Code, which provides as follows: Section 35. Special Budgets for Lump-Sum Appropriations. - Expenditures from lump-sum appropriations authorized for any purpose or for any department, office or agency in any annual General Appropriations Act or other Act and from any fund of the National Government, shd!l be made in accordance with a special budget to be approved by the President, , 'which shall include but shall not be limited to' the huinber of each kind of position, the designations, and the annual salary proposed for which an appropriation is intended. This provision shall be applicable to all revolving funds, receipts which are automatically made available for expenditure for certain spec/fie purposes, aids and donations for carrying out certain activities, or deposits made to cover to cost of special services to be rendered to private parties . Unless otherwise expressly provided by law, when any Board, head of department, chief of bureau or office, or any other official, is authorized to appropriate, allot, distribute or spend any lump-sum appropriation or special, bond, trust, and other funds, such authority shall be subject to the provisions of this section. In case of any lump-sum appropriation for salaries and wages of temporary and emergency laborers and employees, including contractual personnel, provided in any General Appropriation Act or other Acts, the expenditure of such appropriation shall be limited to the employment of persons paid by the month, by the day, or by the hour. (Emphasis supplied) The DBM enumerates the documentary req9irements for the rele<1-se of SAGF: (1) Special Budget Request; (2) Financial Plan; (3) Physical Plan; (ft) Monthly Disbursement Program; (5) Certification of the available balance pf SAGF or Certification of receipt or deposits from the Bureau of Treasury; aiid ( 6) other documentary requirements under existing guidelines. In some casys, additional documents, such as the Signed Revenue Performance Evaluation Board Resolution or the Development Budget Coordination Committ~e 31s Id. rn, Id . I. 377 Pimentel fl! v. Matula, G.R. No. 274778, December 3, 2005 [Per J. Lazaro-Javier, En Banc]. See 2q2s BESF, Glossary of Terms, p. 899. i