The Civil Service Commission had been appropriated P2885,660,790.44 by the General Appropriations Act (GAA) of 2002. However, the total fund released to the commission by the Department of Budget and Management during the fiscal year 2002 was only P279,853,398.14, leaving an unreleased balance of P5,807,392.30.
1. Whether or not DBM may enforce its no report, no release policy on a constitutional commission.
2. Whether or not CSC’s budget may be reduced by Congress lower that that of the previous fiscal year.
1. NO. The no report, no release policy may not be validly enforced against offices vested with fiscal autonomy without violating Article IX-A, Section 5 of the Constitution.
2. YES. Congress is not prohibited from reducing the appropriation of constitutional commissions below the amounth appropriated for them for the previous year. Only the judiciary enjoys such provision.