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 92 G.R. Nos. 271059, 271347, E-02472 and E-04036 Certification, are also required.378 This mechanism ensures executive oversight over the release of designated funds and prevents the uncontrolled release of resources.379 . . ! •. Confederation of Coconut Farmers Organizations of the Philippi~es, Inc., v. Aquino III (Confederation a/Coconut Farmers)380 discussed the nature of, and parameters governing, the valid utilization and disbursement of spetjial funds accruing to a Special Account in the General Fund. This· case ·•· • specifically involved the constitutionality of Executive Order Nos. 179 a'ndI 180, which sought to inventory, privatize, reconvey, and utilize the coco&ut ,levy .funds and assets accumulated under special laws and prior executive issuances.381 Based on Article VI, Section 29 of the 1987 Constitution, the coconut levy funds that accrued to a Special Account in the General Fund ~re special appropriations of "revenue[ s] collected for a special purpose[,]" and should, therefore, "be used exclusively for the stated purpose[.]"382 [... ]The revenue collected for a special purpose shall be treated as a speci;,l fund to be used exclusively for the stated purpose. This serves as a deterrent for abuse in the disposition of special funds. The coconut levy funds are special funds allocated for a specific purpose and can never be used for purposes other than for the benefit of the coconut fanners or the development of the coconut industry. Any attempt to appropriate the said fimds for another reason, no matter how noble or beneficial, would be struck down as unconstitutional. 383 (Emphasis supplied) . While special funds created by special law may be automaticafly appropriated, such automatic appropriation is "not necessar[!y • unconstitutional for as long as there are clear legislative parameters" governing their disbursement by the Executive:384 Thus, E.O. No. 179 does not create a new special fund but merely reiterates that revenues arising out of or in connection with the privatization of coconut levy funds shall be deposited in the SAGF. An automatic appropriation law is not necessarily unconstitutional for as long as there are clear legislative parameters on how the amounts appropriated are to be disbursed. The president should not have unlimited discretion as to its disbursement since the funds are allocated for a specific purpose. In Edu . v. Ericta, the Court explained when a valid delegation of legislative power may be done, viz.: '" Department of Budget and Management, Citizen's Charter 2025 (I" Edition) Table I, P: 34. . '. 379 Anthony Arvin V. Salazar, Ways Forward in Managing Earmarked ~evenues z_n t.he Phzltppmes: Trefds, Issues, and Policy Options, House of Representatives - Cbhgress,onal Policy and Budget Rese<)Ich Department, Issue No. 4 (2026), p. 4. 380 815 Phil. 1036 (2017) [Per J. Mendoza, En Banc]. 381 Id. m !d. at 1053. 383 Id. 384 !d. at I 055.