MANILA — The Supreme Court (SC) has declared unconstitutional the 2024 and 2025 General Appropriations Acts (GAAs), alongside specific provisions within the 2026 national budget, following petitions challenging legislative adjustments that inflated public funds.
In a full court decision, the high tribunal ruled that the 2024 national budget violated the Constitution due to a ₱449.5 billion increase approved by Congress in unprogrammed appropriations, which improperly raised the President’s total recommended appropriations. Similarly, the 2025 GAA was struck down over a congressional approval of a ₱17.99 billion increase in the Special Road Fund, which also breached budget ceiling limits.
For the 2026 national budget, the Court nullified Special Provisions 1(a) and (b) under Chapter XLIII concerning unprogrammed appropriations.
The ruling resolved four separate petitions filed by legislators, taxpayers, and civil society groups—including prominent challenges led by former lawmaker Edcel Lagman and former senator Aquilino “Koko” Pimentel III—which questioned the constitutionality of massive budget inflations introduced by the Bicameral Conference Committee.
The SC stressed that while unprogrammed appropriations are not inherently unconstitutional, they require strict safeguards, transparency, and clear limits to prevent unchecked executive spending authority and preserve fiscal discipline.
The tribunal specifically flagged the “Strengthening Assistance for Government Infrastructure and Social Programs (SAGIP)” item under the 2024 and 2025 budgets as a prohibited lump-sum allocation that unlawfully granted the Executive post-enactment allocative powers.
Despite invalidating the laws, the Supreme Court applied the doctrine of operative fact. This legal principle validates official actions and irreversible programs executed prior to a law being declared void, provided beneficiaries acted in good faith.
Clarifying the bounds of the doctrine, the SC emphasized that it “does not shield authors, proponents, or implementors from criminal, civil, or administrative liability unless the proper tribunals explicitly find that they acted in good faith”.
The decision, penned by Senior Associate Justice Marvic Leonen, was publicly released by the SC Office of the Spokesperson via Viber. Concurrently, the tribunal permanently prohibited key offices—including the Senate, the House of Representatives, the Office of the Executive Secretary, and the Department of Budget and Management—from implementing the invalidated provisions of the 2026 GAA.