Pimentel III vs. House of Representatives

A provision in a general appropriations law that impliedly amends or repeals a substantive law is an unconstitutional rider, and special funds collected and earmarked for a specific purpose — including PhilHealth's reserve funds sourced from sin tax revenues — cannot be diverted to the general fund unless that purpose has been fulfilled or abandoned, pursuant to Article VI, Section 29(3) of the Constitution.

The Universal Health Care Act (R.A. No. 11223, enacted 2019) instituted comprehensive reforms to expand social health insurance coverage for all Filipinos, with Section 11 governing PhilHealth's reserve funds — mandating actuarially estimated ceilings, prescribing exclusive uses for excess reserves, and categorically prohibiting any portion of the reserve fund from accruing to the general fund of the National Government. The Sin Tax Laws (R.A. Nos. 10351, 11346, and 11467) earmark specified percentages of excise tax collections on alcohol, tobacco, sweetened beverages, and vapor products exclusively for the implementation of the UHCA through PhilHealth, making these revenues special funds within the meaning of Article VI, Section 29(3) of the Constitution. PhilHealth, a government-owned and -controlled corporation attached to the Department of Health, administers the National Health Insurance Program and relies on these earmarked sin tax collections, member premiums, and annual government subsidies as its primary funding sources.

On August 2, 2023, President Ferdinand R. Marcos, Jr. submitted to Congress the budget documents for fiscal year 2024, including the Budget Message, the Budget of Expenditures and Sources of Financing (BESF), the National Expenditure Program (NEP), and the Staffing Summary. The NEP recommended PHP 5.7676 trillion in total budget, comprising PHP 4.0198 trillion in programmed appropriations, PHP 1.7478 trillion in automatic appropriations, and PHP 281.9 billion in unprogrammed appropriations. On August 30, 2023, members of the House of Representatives filed House Bill No. 8980, adopting the President's proposed budget. The House approved the bill on Second and Third Readings on September 27, 2023, after President Marcos, Jr. certified it as urgent by Letter dated September 20, 2023 addressed to Speaker Romualdez, citing the need to maintain continuous government operations following the end of the current fiscal year.

The Senate received the bill on November 4, 2023, tackled it on First Reading on November 6, 2023, and approved it on Second and Third Readings on November 28, 2023. The Senate and the House thereafter designated conferees to the Bicameral Conference Committee, which held meetings on November 28 and December 6, 2023. On December 11, 2023, the BCC submitted its Report to both Houses, recommending an increase in unprogrammed appropriations from PHP 281.9 billion to PHP 731.4 billion and inserting Special Provision 1(d) under Chapter XLIII, which authorized the return to the National Treasury of the "fund balance" of government-owned and -controlled corporations from any remainder resulting from the review and reduction of their "reserve funds" to reasonable levels. Both Houses approved the Report on the same day. On December 20, 2023, the President signed House Bill No. 8980 into law as Republic Act No. 11975, the 2024 GAA, which took effect on January 1, 2024.

By virtue of Special Provision 1(d), the DOF issued DOF Circular No. 003-2024 on February 27, 2024, defining "fund balance" as unrestricted funds and requiring GOCCs to remit such balances to the Bureau of the Treasury within fifteen days of receipt of notice. On April 24, 2024, DOF Secretary Ralph Recto instructed PhilHealth to remit PHP 89.9 billion — later clarified as the unutilized government subsidies for indirect contributors from 2021 to 2023, computed by deducting PHP 149.2 billion in total benefit claims for indirect contributors from PHP 239.1 billion in total premiums for indirect contributors. The DOF arrived at this figure by first computing a PHP 183.1 billion "fund balance" — the difference between PhilHealth's PHP 463.7 billion in reserve funds and a PHP 280.6 billion ceiling derived not from actuarial estimation as required by Section 11 of the UHCA, but from a simple averaging of PhilHealth's historical two-year expenditures from 2018 to 2023 — and then selecting the lesser amount of PHP 89.9 billion for remittance.

PhilHealth's Board of Directors approved the transfer, and remittances were made in three tranches: PHP 20 billion on May 10, 2024, PHP 10 billion on August 21, 2024, and PHP 30 billion on October 16, 2024, totaling PHP 60 billion. A fourth tranche of PHP 29.9 billion, scheduled for November 20, 2024, was enjoined by the Court's temporary restraining order. According to petitioners, the PHP 89.9 billion formed part of PhilHealth's "reserve funds" under Section 11 of the UHCA, as PhilHealth's established practice was to transfer its entire annual surplus or net income into its reserve funds at the end of each fiscal year — a characterization the OSG itself confirmed during oral arguments, admitting that the PHP 183.1 billion "fund balance" originated from PhilHealth's reserve funds and was reclassified only to comply with Special Provision 1(d). Respondents maintained that the "fund balance" was distinct from "reserve funds," consisting only of unrestricted, unutilized government subsidies. On September 20, 2025, President Marcos, Jr. publicly announced that the PHP 60 billion remitted to the National Treasury would be returned to PhilHealth.

• Prohibited Rider: Pimentel III et al. argued that Special Provision 1(d) is a prohibited rider violative of Article VI, Section 25(2) of the Constitution because it is not germane to the 2024 GAA — it is inappropriate insofar as it amends the UHCA and the Sin Tax Laws by diverting funds exclusively for PhilHealth to the National Treasury, and it is ambiguous because its implementation requires reference to previous budget and non-budget legislation.
• Excess of Appropriations Power: Pimentel III et al. maintained that the insertion of Special Provision 1(d) exceeds Congress's power to appropriate funds under the Constitution, as it effectively diverts the "reserve funds" of PhilHealth earmarked for the implementation of the UHCA for further appropriation by the Executive.
• Violation of Special Funds Rule: Pimentel III et al. argued that DOF Circular No. 003-2024 violates Article VI, Section 29(3) of the Constitution, which prohibits the transfer of special funds to purposes other than those for which they were created.
• Violation of Cash Budgeting System: Pimentel III et al. contended that DOF Circular No. 003-2024 violates Section 70 of the 2023 GAA because it ordered the return to the National Treasury of supposed unused funds of GOCCs even before the end of Fiscal Year 2024.
• Violation of Right to Health: Pimentel III et al. asserted that Special Provision 1(d) and DOF Circular No. 003-2024 violate the people's constitutional right to health by depriving Filipinos of funds that could increase access to quality and affordable health care.
• Invalid Delegation of Augmentation Power: Atty. Matula et al. argued that under the Constitution, only the President may be authorized by law to augment an item in the GAA from savings, and that Special Provision 1(d) and DOF Circular No. 003-2024 unduly delegated this power to the Secretary of Finance.
• Technical Malversation and Plunder: Atty. Matula et al. submitted that the transfer of idle or unused funds from PhilHealth to the National Treasury constitutes technical malversation of public funds and plunder, as the PHP 89.9 billion belongs to PhilHealth members and is not intended to augment the National Treasury.
• Invalid Presidential Certification: Colmenares et al. averred that the President committed grave abuse of discretion in certifying House Bill No. 8980 as urgent without any public calamity or emergency, violating Article VI, Section 26(2) of the Constitution, and that the certification infringed on Congress's power to deliberate on a bill in three readings on separate days.
• Unconstitutional Increase in Appropriations: Colmenares et al. argued that the BCC's insertion of PHP 449.5 billion under unprogrammed appropriations, increasing the total from PHP 289.1 billion to PHP 731.4 billion, was void for being substantially different from the amount in the NEP, violating the prohibition against increasing the appropriations recommended by the President.
• BCC Exceeded Its Powers: Colmenares et al. maintained that the BCC is not a third house of Congress and is not empowered to perform legislative functions beyond harmonizing differences between the bills passed by each chamber, and that inserting a new item not found in either version was unconstitutional.
• Invalid Delegation and Malversation: 1Sambayan Coalition et al. argued that Special Provision 1(d) is an invalid delegation of authority as the power to transfer savings is exclusively vested in officials enumerated under Article VI, Section 25(5), and that the DOF Secretary arrogated unto himself the authority belonging to the President; they also urged the Court to find the DOF Secretary liable for malversation and/or plunder.

• Absence of Requisites for Judicial Review: The OSG argued that the requisites for the exercise of judicial review were absent and that petitioners violated the doctrine of exhaustion of administrative remedies, including the failure to file a case before the DOF itself.
• Presidential Immunity: The OSG contended that the President was improperly impleaded and must be dropped as a respondent by virtue of presidential immunity from suit.
• Not a Rider: The OSG maintained that Special Provision 1(d) is not a rider because it has a reasonable relation to the 2024 GAA as a source of funds for unprogrammed appropriations, and that it does not amend or repeal the UHCA or the Sin Tax Laws because the concept of "fund balance" is different from "reserve funds."
• Fund Balance Is Not Savings: The OSG argued that "fund balance" is not the same as "savings" under Article VI, Section 25(5), and that Special Provision 1(d) and DOF Circular No. 003-2024 did not emanate from the President's power to transfer savings, hence there was no undue delegation.
• No Violation of Right to Health: The OSG asserted that out-of-pocket expenditure has no relation to the remittance of PhilHealth funds and that the remittance will not hamper the implementation of the UHCA, the issue on benefit packages being a question of policy beyond the Court's jurisdiction.
• Fund Balance Excludes Special Funds: The OSG contended that the fund balance defined under DOF Circular No. 003-2024 does not include special funds from sin tax collections, as it can only include "unrestricted funds."
• No Violation of Cash Budgeting System: The OSG argued that the cash-budgeting system only requires that unutilized amounts remaining at the end of the fiscal year be returned to the National Treasury and does not require reversion only at year-end.
• No Malversation or Plunder: The OSG maintained that the fund balance was not appropriated by law for a specific purpose and thus is not a special fund, and that there was no acquisition of ill-gotten wealth since the funds were remitted to the National Treasury.
• Valid Presidential Certification: The OSG argued that the President's certification was in accordance with the Constitution, as the timely passage of the GAA ensures stability and predictability essential to economic growth, and that Congress itself did not question the certification.
• No Increase in President's Budget: The OSG contended that what Article VII, Section 22 prohibits is an increase in the President's proposed budget as reflected in the BESF, not an increase in unprogrammed appropriations, which is in accordance with Article VI, Section 25(1).
• BCC Powers: The OSG argued that the BCC has the power to modify and add provisions to a bill, as confirmed by the rules of both Houses and by jurisprudence in Tolentino vs. Secretary of Finance.
• PhilHealth's Position: PhilHealth, through the OGCC, asserted that DOF Circular No. 003-2024 complied with the 2024 GAA's guidelines, that the fund balance does not include special funds under Article VI, Section 29(3) as it only covers unrestricted funds, and that even assuming the fund balance is a special fund, the purpose for which it was created had already been fulfilled or abandoned.

• Judicial Review: Whether the requisites for a valid exercise of the expanded power of judicial review are present.
• Presidential Certification of Urgency: Whether the 2024 GAA is unconstitutional for bearing the certification of urgency by the President despite the alleged absence of a public calamity or emergency.
• Constitutionality of Special Provision 1(d) and DOF Circular No. 003-2024: Whether Special Provision 1(d) and its implementing DOF Circular No. 003-2024 are unconstitutional, specifically: (a) whether Special Provision 1(d) is an unconstitutional rider or inappropriate provision in the 2024 GAA; (b) whether the transfer of PhilHealth funds violates the people's right to health, Section 11 of the UHCA, the Sin Tax Laws, and Article VI, Section 29(3) of the Constitution; and (c) whether the DOF is authorized to direct the transfer of savings of GOCCs back to the National Treasury under Article VI, Section 25 of the Constitution.
• Cash Budgeting System: Whether DOF Circular No. 003-2024 violates Section 70 of the 2023 GAA insofar as it orders the transfer of PhilHealth funds to the National Treasury before December 30, 2024.
• Criminal Liability: Whether alleged culpability for technical malversation and/or plunder in the transfer of PhilHealth funds may be adjudged in the present cases.
• Guidelines on Certification: Whether petitioners may properly seek guidelines from the Court on how and when the President may exercise the power to certify a bill for immediate enactment.
• Return of Funds: Assuming Special Provision 1(d) and DOF Circular No. 003-2024 are declared unconstitutional, whether the Court may order the return of the PHP 60 billion PhilHealth funds already transferred to the National Treasury.

• Judicial Review: Yes. All four requisites for the exercise of expanded judicial review are present: an actual case or controversy exists, petitioners have locus standi as direct contributors and taxpayers, the constitutional question was raised at the earliest opportunity, and the constitutionality of the assailed issuances is the very lis mota of the cases.
• Presidential Certification of Urgency: Not unconstitutional. The President did not commit grave abuse of discretion in certifying House Bill No. 8980 as urgent, as public calamity or emergency is not limited to physical calamities and may encompass anything that in the President's reasoned opinion causes harm or disruption to normal life; Congress accepted the certification, and the Court cannot substitute its judgment absent grave abuse of discretion.
• Unconstitutional Rider: Yes. Special Provision 1(d) is an unconstitutional rider — it is ambiguous for introducing the undefined concept of "fund balance" and requiring supplementary DOF guidelines, and it is inappropriate for impliedly amending Section 11 of the UHCA and the Sin Tax Laws by replacing actuarial estimation with arithmetic averaging and diverting reserve funds to the National Treasury contrary to the express prohibition in Section 11.
• Violation of Special Funds and Right to Health: Yes. The transfer violated Article VI, Section 29(3) of the Constitution because sin tax collections earmarked exclusively for UHCA implementation are special funds that cannot be diverted unless the purpose is fulfilled or abandoned — which it manifestly is not — and the diversion infringed the constitutional right to health by depleting resources reserved for affordable, sustainable, and accessible public healthcare insurance.
• DOF Authority to Transfer: No. The DOF Secretary was not authorized to direct the transfer of funds under Article VI, Section 25(5), as the power of augmentation is exclusively vested in the President and other enumerated officials, the funds transferred were not "savings" from the augmenting office's appropriations, and the transfer was not for the purpose of augmenting an item within the same office.
• Cash Budgeting System: Not applicable. The cash budgeting system does not apply to PhilHealth's funds because they are special funds created for a special purpose under Article VI, Section 29(3), and there can be no instance where such funds will remain unobligated.
• Criminal Liability: No. A petition for certiorari and prohibition is not the proper remedy to adjudicate criminal liability for technical malversation or plunder; these must be determined in a proper criminal action with full observance of the accused's constitutional rights.
• Guidelines on Certification: Declined. The Court declined to issue guidelines on the President's exercise of the power to certify a bill as urgent, as the desired guidelines are superfluous and the Constitution is clear on when and why such certification is issued; the Court also declined to issue parameters for the BCC, deferring those issues to related pending cases.
• Return of Funds: Yes. The PHP 60 billion must be returned to PhilHealth, as the doctrine of operative fact is inapplicable given that the State is presumed solvent, the funds are special funds held in trust for the people's right to health, and the retention of the funds would constitute a continuing violation of the right to health.

• Judicial Review: The Court found that an actual case or controversy exists because PHP 60 billion had already been remitted to the National Treasury, presenting a prima facie showing of grave abuse of discretion. The doctrines of hierarchy of courts and exhaustion of administrative remedies were excused because the petitions raise pure questions of law of transcendental importance, and ordinary remedies were plainly inadequate given the magnitude of the funds involved. Petitioners established standing both in the traditional mode — as direct contributors to the NHIP who stand to be directly injured by the assailed acts — and in the nontraditional mode — as citizens-taxpayers assailing an alleged illegal disbursement of public funds. The constitutional question was raised at the earliest opportunity during the lifetime of the 2024 GAA and DOF Circular No. 003-2024, and the constitutionality of the assailed issuances is the very lis mota, as the validity of the transfer cannot be disposed of on any other ground without constitutional adjudication.

• Presidential Certification of Urgency: The Court held that the President's decision to certify a bill as urgent is a matter of policy within his full and binding discretionary power, and that public calamity or emergency is not restricted to physical calamities but refers to anything that in the President's reasoned opinion causes harm, suffering, or damage, including disruptions to normal life. The timing need not be a present occurrence; a mere possibility of future harm suffices. The Court took judicial notice that Congress accepted the certification, and held that Congress is the sole judge of the sufficiency and propriety of the urgency certification. Absent grave abuse of discretion, the Court is enjoined by the principle of separation of powers to give due deference to a co-equal branch. The Court relied on Tolentino vs. Secretary of Finance in holding that a presidential certification dispenses with both the three-reading requirement and the printing and distribution requirement.

• Unconstitutional Rider: The Court applied the test of germaneness from Atitiw vs. Zamora, requiring that a provision in a general appropriations bill be particular, unambiguous, and appropriate. While Special Provision 1(d) was particular — relating to unprogrammed appropriations — it was ambiguous because it introduced the undefined concept of "fund balance," left "reasonable levels" without objective criteria, and required supplementary DOF guidelines to operationalize it, constituting an undue delegation of legislative power. More critically, the provision was inappropriate because it impliedly amended Section 11 of the UHCA: the DOF replaced the actuarial estimation mandated by Section 11 with a simple arithmetic averaging method, yielding a lower ceiling (PHP 280.6 billion versus the actuarially estimated PHP 560.55 billion), then used this lower ceiling to carve out a PHP 183.1 billion "fund balance" from PhilHealth's reserve funds and require its remittance to the National Treasury — directly contravening Section 11's express prohibition against any portion of the reserve fund accruing to the general fund. The Court found that the "fund balance" originated from and was part of PhilHealth's "reserve funds," as confirmed by the OSG's own admissions during oral arguments, and that christening a portion of the reserve funds by another name does not alter its restricted nature. The Court also found that Special Provision 1(d) impliedly amended the Sin Tax Laws, which mandate that specified percentages of excise tax collections "shall be allocated and used exclusively" for UHCA implementation — an unqualified earmark that Congress has no discretion to reduce or withhold.

• Violation of Special Funds and Right to Health: The Court held that sin tax collections earmarked for PhilHealth are special funds under Article VI, Section 29(3) of the Constitution, which requires only that the tax be levied for a special purpose — not that the funds be segregated in a special account. The constitutional description of a fund as "special" is established from the moment of its creation and does not change by reason of flaws or lapses in its execution. The purpose for which the special fund was created — universal health care — has neither been fulfilled nor abandoned, as PhilHealth's own President and CEO admitted that the UHCA's goals remain unfulfilled six years into implementation. The diversion of PhilHealth's reserve funds also violated the constitutional right to health under Article II, Section 15 and Article XIII, Section 11, which the Court recognized as self-executing and encompassing the right to affordable, accessible, and sustainable public healthcare insurance. The UHCA was enacted to transform this right into a legally demandable entitlement, and Special Provision 1(d) undermined the UHCA's legal architecture by diverting funds that could have been used to expand benefits and reduce member contributions.

• DOF Authority to Transfer: The Court held that the transfer violated Article VI, Section 25(5) of the Constitution because none of the three requisites for valid augmentation were met: the Secretary of Finance is not among the officials enumerated in the provision and cannot exercise the power of augmentation even as the President's alter ego; the funds transferred were not "savings" generated from the appropriations of the Office of the President but were PhilHealth's restricted reserve funds; and the transfer was not made to augment an item in the GAA for the same office. The Court rejected the OSG's disavowal of augmentation, holding that the undeniable consequence of the measures was the transfer and realignment of funds, and that what cannot be done directly cannot be done indirectly. The cross-border transfer of funds violated the constitutional prohibition against moving funds across institutional boundaries.

• Cash Budgeting System: The Court held that the cash budgeting system under Section 70 of the 2023 GAA finds no application to PhilHealth's funds because they are special funds created for a special purpose under Article VI, Section 29(3). While PhilHealth's funds may be unspent at a given time, there can be no unobligated funds to speak of, as they are exclusively appropriated for the people's right to health.

• Criminal Liability: The Court declined to determine criminal liability because a petition for certiorari and prohibition is a special civil action limited to a determination of grave abuse of discretion, not a proper vehicle for adjudging criminal liability. Rule 1, Section 3 of the 2019 Amendments to the Rules of Civil Procedure distinguishes civil actions from criminal actions, and the finding of criminal guilt requires a full criminal trial with observance of the accused's constitutional rights.

• Guidelines on Certification: The Court declined to issue guidelines on the President's certification power, finding them superfluous since the Constitution is clear on when and why certification is issued, and Congress is the sole judge of its sufficiency. The Court also deferred resolution of issues regarding the BCC's creation, powers, and actions to related pending cases (G.R. No. 277975 and G.R. Nos. 271059 & 271347).

• Return of Funds: The Court ordered the return of PHP 60 billion to PhilHealth, holding that the doctrine of operative fact — an equitable exception to the general rule that unconstitutional laws produce no effects — was inapplicable. The nature of the funds taken (special funds for the right to health), the State's presumed solvency, the Secretary of Finance's own admission that the government could comply with a directive to return the funds, and the fact that petitioners challenged the measures from the outset all weighed against applying the doctrine. The Court noted that the President himself had publicly announced the return of the funds, and ordered respondents to include a specific item in the 2026 GAA for the return, in addition to PhilHealth's regular budgetary appropriation.

• Test of Germaneness for Appropriations Bills — A provision in a general appropriations bill complies with the test of germaneness if it is particular (relates specifically to a distinct item of appropriation), unambiguous (its application is apparent on the face of the bill without reference to external sources), and appropriate (its subject matter does not require separate legislation). Provisions that are ambiguous — requiring supplementary administrative guidelines to operationalize undefined concepts — or that impliedly amend or repeal existing substantive laws are unconstitutional riders. The Court applied this test to strike down Special Provision 1(d) for introducing the undefined concept of "fund balance" and for impliedly amending Section 11 of the UHCA by replacing actuarial estimation with arithmetic averaging.

• Special Funds Doctrine (Article VI, Section 29(3)) — All money collected on any tax levied for a special purpose shall be treated as a special fund and paid out for such purpose only. The constitutional classification of a fund as "special" is established from the moment of its creation and is determined by the legislative intent and purpose of the tax, not by the technical or accounting management of the funds. The fact that special funds are commingled with the general fund does not divest them of their character as special funds. The only exception permitting transfer to the general fund is when the purpose for which the special fund was created has been fulfilled or abandoned. The Court held that sin tax collections earmarked exclusively for UHCA implementation through PhilHealth are special funds, and that the UHCA's purpose remains unfulfilled.

• Prohibition Against Amendment Through the GAA — Congress cannot amend or repeal substantive laws through a general appropriations act; any amendment must be enacted in a separate law. A provision in the GAA that impliedly repeals or amends an existing substantive law is an "inappropriate provision" that is void. The Court applied this doctrine to hold that Special Provision 1(d) could not validly amend Section 11 of the UHCA or the Sin Tax Laws through the 2024 GAA.

• Power of Augmentation (Article VI, Section 25(5)) — The power to augment items in the GAA from savings is exclusively vested in the President, the President of the Senate, the Speaker of the House of Representatives, the Chief Justice, and the heads of Constitutional Commissions. This power cannot be delegated to alter egos or department heads. Three requisites must concur: (1) a law authorizing the official to transfer funds; (2) the funds are savings from the appropriations of the augmenting official's own office; and (3) the transfer is to augment an item in the GAA for the same office. Cross-border transfers of funds are prohibited. The Court held that the DOF Secretary's directive to transfer PhilHealth's reserve funds failed all three requisites.

• Doctrine of Operative Fact — An unconstitutional law produces no legal effects, but the doctrine of operative fact serves as an equitable exception, allowing the effects of an unconstitutional law prior to its judicial declaration of nullity to be left undisturbed. The doctrine cannot be invoked to perpetuate inequity or injustice, and it is inapplicable where: (a) the challenging party contested the measure's validity from the outset; (b) there is no compelling inequity in ordering return; and (c) the State is capable of restitution. The Court held the doctrine inapplicable to the PHP 60 billion transferred from PhilHealth, ordering its return.

• Presidential Certification of Urgency — The President's certification of a bill's immediate enactment to meet a public calamity or emergency dispenses with both the three-reading requirement and the printing and distribution requirement. Public calamity or emergency is not limited to physical disasters but encompasses anything that in the President's reasoned opinion causes harm, suffering, or damage, including disruptions to normal life. Congress is the sole judge of the sufficiency and propriety of the certification, and the Court cannot overrule the wisdom of the President and Congress absent grave abuse of discretion.

• "If PhilHealth's 'fund balance' was hatched from PhilHealth's 'reserve funds' and swam as PhilHealth's 'reserve funds' to the National Treasury, then these 'reserve funds,' no matter how they were labelled subsequently, are still PhilHealth's 'reserve funds.'" — This passage captures the Court's critical finding that the "fund balance" remitted to the National Treasury was in truth part of PhilHealth's legally restricted reserve funds, confirmed by the OSG's own admissions during oral arguments, and that recharacterization cannot alter the restricted nature of the funds.

• "The right to health is not abstract philosophy. It is the heartbeat of the right to life—the foundation on which all other freedoms stand. It is primus inter pares—first among equals—in the constellation of rights that uphold human dignity." — This passage from the prefatory statement articulates the Court's framing of the right to health as a fundamental, enabling right that undergirds all other constitutional guarantees, setting the doctrinal tone for the decision.

• "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 classification of the fund as 'special fund.'" — This passage establishes that the constitutional characterization of a fund as "special" under Article VI, Section 29(3) is determined by the purpose for which the tax was levied, not by how the fund is administratively managed or whether it is segregated from the general fund.

• "The handling of the fund and its segregation from the general fund is merely an administrative matter that will neither affect nor alter its character." — This formulation clarifies that the special fund character attaches at creation and is constant, reinforcing the principle that administrative lapses in fund management cannot be used to defeat constitutional protections for earmarked revenues.

• Belgica vs. Ochoa, 721 Phil. 416 (2013) — Controlling precedent on judicial review of budget-related legislation and the definition of "appropriation." The Court relied on Belgica to establish that taxpayers have standing to sue where public funds are illegally disbursed, and that the Court cannot heed pleas for judicial restraint when constitutional boundaries must be allocated. Also cited for the principle that unprogrammed appropriations are part of the "budget" under Article VI, Section 25(1).

• Philippine Constitution Association vs. Enriquez, 305 Phil. 546 (1994) — Controlling precedent on inappropriate provisions in the GAA. The Court followed Philconsa in holding that provisions intended to amend other laws are "inappropriate provisions" with no place in an appropriations bill, and that the power of augmentation under Article VI, Section 25(5) must be exercised only by the President alone.

• Atitiw vs. Zamora, 508 Phil. 321 (2005) — Controlling precedent on the test of germaneness. The Court applied the three-pronged test (particular, unambiguous, appropriate) to find Special Provision 1(d) ambiguous and inappropriate.

• Tolentino vs. Secretary of Finance, 305 Phil. 686 (1994) — Followed on the effect of presidential certification of urgency, specifically that it dispenses with both the three-reading requirement and the printing and distribution requirement.

• Araullo vs. Aquino III, 737 Phil. 457 (2014) — Followed on the requisites for valid augmentation and the definition of "savings," establishing that savings must come from the appropriations of the augmenting office itself.

• Demetria vs. Alba, 232 Phil. 222 (1987) — Followed on the prohibition against cross-border transfers of appropriations, holding that the Constitution meticulously crafted safeguards against misappropriation and embezzlement of public funds.

• Gaston vs. Republic Planters Bank, 242 Phil. 377 (1988) — Followed on the nature of special funds, establishing that stabilization fees levied for a special purpose are special funds administered in trust for the purpose intended.

• Governor Mandanas vs. Romulo, 473 Phil. 806 (2004) — Followed on the principle that Congress may not amend substantive laws through the GAA, as any amendment must be done in a separate law.

• Guiao vs. PAGCOR, 955 Phil. 40 (2024) — Followed on the principle that unqualified statutory remittances must be strictly complied with, applied to the sin tax earmarks for PhilHealth.

• Municipality of Tupi vs. Faustino, 860 Phil. 363 (2019) — Followed on the inapplicability of the operative fact doctrine where the State is capable of restitution and the challenging party contested the measure from the outset.

• De Lima vs. President Duterte, 865 Phil. 578 (2019) — Followed on presidential immunity from suit, applied to drop President Marcos, Jr. as a respondent.

• Francisco Jr. vs. House of Representatives, 460 Phil. 830 (2003) — Followed on the standard for determining justiciability despite the invocation of the political question doctrine.

• Article VI, Section 25(2), 1987 Constitution — Requires that all provisions in a general appropriations bill relate specifically to some particular appropriation therein. Applied to find Special Provision 1(d) an unconstitutional rider for being ambiguous and for impliedly amending the UHCA and Sin Tax Laws.

• Article VI, Section 25(5), 1987 Constitution — Authorizes only the President, the President of the Senate, the Speaker of the House, the Chief Justice, and the heads of Constitutional Commissions to augment items in the GAA from savings in other items of their respective appropriations. Applied to hold that the DOF Secretary's directive to transfer PhilHealth's reserve funds constituted an unauthorized exercise of the power of augmentation and an invalid cross-border transfer.

• Article VI, Section 29(3), 1987 Constitution — Mandates that all money collected on any tax levied for a special purpose shall be treated as a special fund and paid out for such purpose only, with transfer to the general fund permitted only if the purpose has been fulfilled or abandoned. Applied to hold that sin tax collections earmarked for UHCA implementation are special funds that cannot be diverted to the National Treasury.

• Article VI, Section 26(2), 1987 Constitution — Prescribes the three-reading requirement and the exception for presidential certification of urgency. Applied to uphold the President's certification of House Bill No. 8980 as not unconstitutional.

• Article II, Section 15, 1987 Constitution — Declares that the State shall protect and promote the right to health of the people and instill health consciousness among them. Applied to hold that the diversion of PhilHealth's reserve funds infringed the constitutional right to health.

• Article XIII, Section 11, 1987 Constitution — Mandates the State to adopt an integrated and comprehensive approach to health development, endeavoring to make essential goods, health, and other social services available to all at affordable cost. Applied as the constitutional basis for the right to affordable, accessible, and sustainable public healthcare insurance.

• Section 11, Republic Act No. 11223 (Universal Health Care Act) — Governs PhilHealth's reserve funds, requiring actuarially estimated ceilings, mandating that excess reserves be used to increase benefits and decrease contributions, and prohibiting any portion of the reserve fund from accruing to the general fund. Applied to hold that Special Provision 1(d) impliedly amended Section 11 by replacing actuarial estimation with arithmetic averaging and by diverting reserve funds to the National Treasury.

• Section 37, Republic Act No. 11223 (Universal Health Care Act) — Enumerates the sources of appropriations for UHCA implementation, including incremental sin tax collections, PAGCOR income, PCSO Charity Fund, premium contributions, and annual government subsidies. Applied to establish that PhilHealth's funding sources are fixed by law and merely pass through the GAA for release.

• Section 288-A, National Internal Revenue Code (as amended by R.A. Nos. 11346 and 11467) — Earmarks specified percentages of excise tax collections on sweetened beverages, alcohol, tobacco, heated tobacco, and vapor products exclusively for UHCA implementation through PhilHealth. Applied to hold that these earmarked revenues are special funds under Article VI, Section 29(3) and cannot be diverted to fund unprogrammed appropriations.

• Section 70, Republic Act No. 11936 (2023 GAA) — Provides for the cash budgeting system, requiring unexpended or undisbursed funds to revert to the unappropriated surplus of the General Fund after the end of the validity period. Applied to hold that the cash budgeting system does not apply to PhilHealth's funds because they are special funds.

• Section 77, Insurance Code — Provides that payment of premium is the operative requisite for insurance coverage. Applied to underscore that PhilHealth's premiums — whether from direct or indirect contributors — are the elixir vitae of the insurance business and cannot be diminished once paid.

Chief Justice Alexander G. Gesmundo concurred fully.

Associate Justice Alfredo Benjamin S. Caguioa concurred in the result, writing separately to emphasize that the GAA functions merely as a release document for PhilHealth's earmarked funds and that Congress exceeded its authority when it increased unprogrammed appropriations from PHP 281.9 billion to PHP 731.4 billion, violating Article VI, Section 25(1).

Associate Justice Jhosep Y. Lopez concurred, writing to stress the UHCA's importance as landmark legislation and to express reservations against the wholesale invalidation of Special Provision 1(d) and DOF Circular No. 003-2024, advocating an as-applied challenge limited to PhilHealth.

Associate Justice Japar B. Dimaampao concurred on the transfer's invalidity but expressed reservations on the deferral of BCC-related issues and the wholesale invalidation of Special Provision 1(d), arguing the increase in unprogrammed appropriations should have been declared unconstitutional and that Special Provision 1(d) should have been held inapplicable to PhilHealth rather than void per se.

Associate Justice Rodil V. Zalameda concurred with reservations, writing to highlight indicia of government good faith, including consultations with OGCC, GCG, and COA, and to caution against extending the ruling to PDIC's fund transfer.

Associate Justice Samuel H. Gaerlan concurred, writing to emphasize that the DOF Secretary was fulfilling his legal duty in issuing DOF Circular No. 003-2024 and should not be held criminally liable.

Associate Justice Ricardo R. Rosario concurred in the result, writing to reinforce the unconstitutionality of Special Provision 1(d) and to clarify that no criminal liability for plunder or technical malversation may be found in these proceedings.

Associate Justice Maria Filomena D. Singh concurred, writing separately to underscore the implications for health system governance, the wide gap in healthcare coverage among the poor, and the ambiguity of Special Provision 1(d).

Associate Justice Antonio T. Kho, Jr. left a concurring vote while on official business.

Associate Justice Ramon Paul L. Hernando concurred in part and dissented in part (see Notable Dissenting Opinions below).

• Senior Associate Justice Marvic M.V.F. Leonen — Concurred that Special Provision 1(d) is unconstitutional but dissented on three grounds: (1) the President's certification of urgency was unconstitutional because the passage of the GAA is not an unforeseeable event and Article VI, Section 25(7) provides for automatic reenactment of the prior year's GAA if Congress fails to pass a new one; (2) Congress's increase of unprogrammed appropriations by PHP 449.5 billion violated Article VI, Section 25(1), which prohibits Congress from increasing the appropriations recommended by the President, as unprogrammed appropriations are part of the total recommended budget; and (3) as a consequence of these constitutional infirmities, the entire 2024 GAA should be declared unconstitutional, with the 2023 GAA deemed reenacted. SAJ Leonen also argued that the BCC's same-day submission and approval of its report, containing massive changes across 43 departments, denied members of Congress meaningful scrutiny.

• Associate Justice Ramon Paul L. Hernando — Concurred that the transfer of PHP 89.9 billion from PhilHealth was unconstitutional but dissented on the validity of unprogrammed appropriations in general. Justice Hernando argued that the inclusion of unprogrammed appropriations in the GAA is itself unconstitutional because Article VII, Section 22 requires the President to submit "a budget of expenditures and sources of financing," and the conjunctive "and" implies that all expenditures in the GAA must be backed by guaranteed sources of financing — which unprogrammed appropriations, by definition, lack. He further argued that unprogrammed appropriations are riders under Article VI, Section 25(2) because they do not relate to any appropriation for expenditures with sources of financing, and that the proper vehicle for excess or new revenue collections is a special appropriations bill under Article VI, Section 25(4). Justice Hernando also argued that the DOF's miscomputation of PhilHealth's reserves — using arithmetic averaging instead of actuarial estimation — was a direct violation of Section 11 of the UHCA, and that the DOF exceeded its fiscal oversight authority over PhilHealth.