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 95 G.R. Nos. 271059, 271347, E-02472 and E"04036 the fund by its administrator or user should not alter how the Constitution characterizes this fund to be. The fact that the sin tax collections are not booked in a special account does not divest it of its nature as a special fund. It is the legislative intent and purpose of the tax, not the technical or accounting management of the funds, that controls. Improper handling or failure to segregate funds may be considered administrative discretion or lapses, but they do not negate the constitutional class/fication o_fthe.fund as "special.fund." The designation of the funds as a special fund is conferred by the Constitution, but the handling of the ftmd and its segregation from the general fund is merely an administrative matter that will neither: affect nor alter its character.391 (Citations omitted; emphasis supplied) ' The special nature of a special fund ends only upon the fulfillment or abandonment of the special purpose for which it was created, consistent with Article VI, Section 29(3). Diverting funds earmarked for a special purpose, therefore, violates the nature of the special fund and is prohibited by Article VI, Section 29(3).392 Thus, in Pimentel III, the Court ruled that the use of PhilHealth's reserve funds, sourced from earmarked excise taxes, to finance programs and projects under the Unprogrammed Appropriations of the 2024 GAA, violated the prohibition under Article VI, Section 29(3) of the Constitution.393 As applied to the alleged increase of the amounts of the Special Accounts in the General Fund (G.R. E-02472): The petitioners in G.R. No. E-02472 assail the constitutionality of the increase in the amounts of the SAGF under the· 2025 Budget through the "upward adjustments" made by the Bicameral Conference Committee.394 According to petitioners, these "upward adjustments," including the increases made to the Special Road Fund, violate Article VI, Section 25(1) of the Constitution. The SAGFs that were increased through the Bicameral Conference Committee, and the laws that create and regulate them, are as follows: Particulars Legal Basis Dcoartment of Agriculture Department of AQriculture - Office of the Secretarv Agricultural Competitiveness SEC. 8. Agricultural Competitiveness Enhancement Fund (ACEF)395 Enhancement Fund. -To implement the policy enunciated in this Act, there is hereby created the Agricultural Comnetitiveness Enhancement 391 Id. 392 Id. 393 Id. YN Petition (G.R. No. E-02472), par. 5.21. 395 Republic Act Nos. 8178, 9496, 10848 (1996, 2008, 2016).