Last reviewed: October 21, 2026
Former President Rodrigo Duterte warned in January 2025 that alleged discrepancies and blank entries in the national budget could make the legislation invalid. Vice President Sara Duterte also criticized how Congress handled government appropriations.
In October 2026, the Supreme Court declared the 2024 and 2025 General Appropriations Acts unconstitutional and invalidated specific provisions of the 2026 budget.
The similarities have prompted renewed debate about whether the earlier warnings were vindicated.
But an important question deserves a careful answer: Did the Supreme Court confirm the Dutertes’ specific allegations, or did it find different constitutional violations?
The available records show overlapping concerns about budget transparency and legality, but they do not establish that every earlier allegation was proven.
What Were the Duterte Budget Warnings?
On January 18–19, 2025, former President Rodrigo Duterte and then-Davao City Representative Isidro Ungab publicly questioned the 2025 national budget.
Their concerns focused on alleged missing amounts and discrepancies in the bicameral conference committee report.
Ungab identified entries involving the Department of Agriculture and unprogrammed appropriations that he said were incomplete.
Rodrigo Duterte argued that material blanks in legislation could undermine its validity. He questioned whether the budget had been properly finalized before approval.
These were allegations about the legislative document and its approval process.
They were not, at that point, judicial findings.
The distinction between the bicameral conference committee report and the final signed General Appropriations Act is central. A discrepancy alleged in one document does not automatically establish that the enacted law contained the same omission.
What Did President Marcos Say in January 2025?
President Ferdinand Marcos Jr. rejected the claims.
In an official statement published by the Presidential Communications Office on January 20, 2025, the President maintained that a General Appropriations Act could not validly contain unspecified budget amounts of the kind alleged.
Executive Secretary Lucas Bersamin subsequently denied that the Executive had participated in any supposed blank-item arrangement.
The administration pointed to the officially published GAA as the document readers should examine.
These responses are part of the public record.
They establish the position of the Marcos administration at the time—not an independent judicial determination that every contested bicameral document was accurate.
What Had Vice President Sara Duterte Warned About?
Vice President Sara Duterte raised broader concerns about political influence over the national budget.
In September 2024, she publicly alleged that then-House Speaker Martin Romualdez and former House appropriations chair Elizaldy Co exercised excessive control over budget allocations.
Co disputed her accusations and argued that budget decisions involved the wider legislative process.
The allegations occurred amid disagreements over the proposed 2025 budget of the Office of the Vice President.
This context matters because statements about political control must be distinguished from proof of a particular constitutional violation.
On October 21, 2026, Sara Duterte welcomed the Supreme Court’s decision and called for President Marcos and lawmakers to answer for the unconstitutional budgets.
She also criticized the bicameral conference committee’s handling of appropriations.
Her calls for accountability are documented public positions. They do not independently establish the personal guilt of the officials she criticized.
The Earlier Warning About the 2024 Budget
Another important figure deserves attention.
On December 13, 2023, then-Senate Minority Leader Aquilino “Koko” Pimentel III questioned the constitutionality of a substantial increase in unprogrammed appropriations in the proposed 2024 national budget.
His objection focused on whether Congress had effectively increased total appropriations beyond the amount recommended by the President.
This concern was much closer to the constitutional question eventually addressed by the Supreme Court.
The Court’s October 2026 ruling partly granted the petition brought by Pimentel and other petitioners.
This is significant because the history of opposition to the disputed appropriations involved several individuals and groups, not only the Duterte family.
What Did the Supreme Court Actually Decide?
The Supreme Court announced three central findings.
First, the 2024 GAA: Congress increased unprogrammed appropriations by approximately ₱449.5 billion, raising total appropriations beyond the President’s recommendation.
Second, the 2025 GAA: The Court found an unconstitutional increase of approximately ₱17.99 billion in the DPWH Special Road Fund. It also identified an unlawful ₱12.75 billion increase involving certain Special Accounts in the General Fund.
Third, the 2026 GAA: The Court invalidated specified provisions governing the release of unprogrammed appropriations.
The ruling also addressed insufficient spending standards, the use of lump-sum mechanisms such as SAGIP, and the importance of transparent budget reconciliation.
The Court’s findings concern identifiable constitutional and statutory restrictions.
They should not be expanded into broader conclusions unsupported by the decision.
Claims Versus Findings: A Documentary Comparison
| Earlier concern | What the October 2026 ruling establishes |
|---|---|
| Rodrigo Duterte questioned alleged blank entries in the 2025 bicameral report | The ruling invalidated the 2025 GAA on identified appropriation grounds; it does not, by itself, prove every alleged blank entry |
| Sara Duterte alleged undue control over budget decisions | The Court identified unlawful budget mechanisms and transparency concerns, but did not thereby establish her accusations against every named politician |
| Koko Pimentel questioned a large increase in 2024 unprogrammed appropriations | The Court expressly found the ₱449.5 billion increase constitutionally impermissible |
| Critics questioned broad spending discretion | The Court required clearer limits and safeguards and rejected specified lump-sum and release mechanisms |
This comparison demonstrates why the phrase “the warnings were proven right” needs qualification.
Some constitutional objections substantially overlap with the Court’s findings. Other allegations concern facts and possible misconduct that require separate evidence.
What Do the Records Not Establish?
The ruling does not automatically prove that the entire ₱449.5 billion or ₱17.99 billion was stolen.
It does not establish that every budget item was disbursed.
It does not establish that every person who signed, supported, or implemented the budgets acted with criminal intent.
And it does not independently resolve every dispute over the contents of the original bicameral reports.
The Court protected certain irreversible actions involving good-faith beneficiaries while leaving open possible proceedings involving responsible officials.
A determination of unconstitutional spending authority is serious. But proving personal wrongdoing requires additional evidence and appropriate legal proceedings.
What Additional Records Should Be Examined?
The strongest next step for document-based accountability is to compare the relevant National Expenditure Programs, bicameral conference committee reports, enacted GAAs, and actual fund-release records.
The Supreme Court’s official consolidated-case page identifies filings and budget documents connected to the litigation.
Additional records from the Department of Budget and Management and the Commission on Audit would help establish which appropriations were released, where the money went, and whether the spending complied with applicable rules.
A complete documentary investigation must distinguish authorization, release, obligation, expenditure, and actual project completion.
Those are not interchangeable events.
PHExpat Bottom Line
The October 2026 ruling supports serious concerns about the constitutional handling of Philippine national budgets.
Rodrigo Duterte’s January 2025 objections and Sara Duterte’s criticisms form part of that history, but their claims should be compared individually against the judicial findings.
Koko Pimentel’s December 2023 objection to increased unprogrammed appropriations is an especially direct example of a warning later addressed by the Court.
The reliable conclusion is neither that every allegation was vindicated nor that earlier criticisms were irrelevant.
The records establish specific constitutional violations. Questions about other alleged irregularities, individual responsibility, and misuse of public funds require separate proof.
Sources and Records
- Supreme Court — Consolidated GAA Cases and filed documents
- 1987 Philippine Constitution
- GMA News — Koko Pimentel’s December 2023 objection
- GMA News — Sara Duterte’s September 2024 accusations and responses
- GMA News — Rodrigo Duterte and Isidro Ungab’s January 2025 objections
- Presidential Communications Office — Marcos’s January 20, 2025 response
- Presidential Communications Office — Executive Secretary’s January 2025 statement
- Philstar — Detailed October 2026 ruling coverage
- GMA News — Vice President’s October 21, 2026 reaction
Editorial disclosure: This is a documentary comparison of published statements, official records, and the Court’s publicly reported findings. It is not an independent forensic audit of all appropriations or a determination of any individual’s criminal responsibility. Further review of the full judgment and underlying fiscal records may require updates.
