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 which provides:
Sec. 5. The Commission shall enjoy fiscal autonomy. Their approved appropriations shall be automatically and regularly released.The automatic release of approved annual appropriations to a constitutional commission vested with fiscal autonomy should thus be construed to mean that no condition to fund releases to it may be imposed. (Civil Service Commission vs. DBM, G.R. No. 158791, July 22, 2005)
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