Supreme Court declares PDAF unconstitutional in Belgica v Executive Secretary

The Supreme Court En Banc unanimously ruled on November 19, 2013 in the consolidated case of Belgica v. Executive Secretary (G.R. No. 208566 and companion cases) that the Priority Development Assistance Fund mechanism as it had operated under successive General Appropriations Acts violated the constitutional separation of powers and the principle of non-delegability of legislative power. The Court held that PDAF improperly allowed individual legislators to identify, modify, and intervene in the execution of specific projects after appropriation, functions that belong constitutionally to the executive branch. The decision permanently enjoined the implementation of PDAF and of the executive's parallel "presidential pork" mechanisms cited in the same petition. It did not, however, prevent the appropriation of funds for the same beneficiaries through identified projects in the GAA itself, a distinction that shaped post-PDAF budget design. The ruling did not address the criminal liability of legislators who had directed PDAF allocations to bogus NGOs; those proceedings continued separately in the Office of the Ombudsman and the Sandiganbayan.