12.10 We recommended that the Provincial Development Council, when
endorsing programs, projects and activities to the Sangguniang
Panlalawigan for approval, specify the particular projects to be funded as
required under Article 454(d) of the IRR of RA No. 7160. For
appropriations that have been presented in lump sum or in generic terms,
a separate SP appropriation ordinance/resolution must be secured by the
Local Chief Executive before utilizing the funds, as required under Section
22(c) of RA No. 7160.
12.11 The Provincial Budget Officer, in her letter dated March 3, 2025, contended that
the “Electrification Program to Various Barangays, Provincewide” under the
20% Development Fund should not be regarded as a general appropriation and,
therefore, should not require a separate SP appropriation for its implementation.
She explained that the project underwent review by various committees of the
Executive Department, including the Local Finance Committee (LFC) and the
Provincial Development Council (PDC), and was subsequently approved by the
Sangguniang Panlalawigan.
12.12 Furthermore, Management cited previous projects, such as the “Streetlighting
in Different Barangays” funded under the Gender and Development (GAD)
Fund in CY 2020, as comparable cases where fund utilization was carried out
under similar conditions.
12.13 Management is reminded that Appropriation Ordinance No. 27, s. 2023, does
not provide a specific, itemized breakdown of the projects to be implemented
under the Electrification Program.
12.14 As stated in Article 454(d) of the IRR of RA No. 7160, appropriations for
development projects must be itemized rather than presented as lump sum
amounts. The absence of a detailed appropriation ordinance specifying the
particular expenditure components necessitates a separate Sanggunian
authorization before fund utilization.
12.15 Furthermore, on February 14, 2024, the Department of Budget and Management
(DBM), in its review of the FY 2023 Supplemental Budget (SB) Nos. 11-23,
which includes Appropriation Ordinance No. 27, s. 2023, declared the budget
operative, subject to the condition stated in Item 13 which, provides:
“ That the utilization of all items in the appropriations including the
Capital Outlay and Capital Expenditures under the General Fund-
Proper and the Local Development Fund shall as may be
applicable, be subject to the authorization of the sanggunian
on the list of projects to be implemented as ruled by the
Supreme Court in the case of Hon. Gabriel Luis Quisumbing,
et.al., vs. Hon. Gwendolyn F. Garcia, et.al., G.R. No. 175527,
08 December 2008.1” (Emphasis supplied)
1 Excerpts from Supreme Court Decision on G.R. No. 175527, 08 December 2008 – “The question of whether a sanggunian authorization
separate from the appropriation ordinance is required should be resolved depending on the particular circumstances of the case. Resort
to the appropriation ordinance is necessary in order to determine if there is a provision therein which specifically covers the expense to
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