not be subjected to reduced expenditure. She also recommends that government's empioyment activation policies must be pursued within a human rights framework that promotes nondiscrimination and equality, equal access to training programs, consideration for gender circumstances, and must be complemented by participatory mechanisms. (Carmona, 201 1) Levet of Public Spending Consistent with Human Rights Admittedly, from a human rights standpoint, it is harder to determine how much the Philippines should spend to progressively realize human rights. There is no domestic or international threshold that quantifies in financial terms exactly how much "maximum available resources" refers to, and how much to spend to progressively realize each human right. Yet, estimating available financial resources and resource requirements to realize human rights is not only possible; it may yield less expensive costs than anticipated. For example, Manasan (2007) estimated the amount of financial resources needed to achieve the MDG goals related to poverty reduction, education, health, water and sanitation using both high and low cost assumptions, and related these to the country's available resources under both MTPDP and Iow GDP growth projections to arrive at resource gaps. Her estimates show cumulative resource gaps amounting to less than one percent of the country's GDP. Assumptions High Cost/MTPDP growth rate High Cost/Low GDP rate Low Cost/MTPDP growth rate Low Cost/Low GDP rate Available Resources 3.17 3.12o/o of GDP 2.97 3.09 % of GDP 3.17 3.12o/o of GDP 2.97 3.09/" of GDP Required Resources 3.97 3.88% of GDP 3.97 4.160/o of GDP 3.77 3.71% of GDP 3.77 3.98% of GDP Resource Gap 777.98 0.76% of GDP 1T '1.07o/o of GDP 605.28 0.59% of GDP B4BB O.89/" of GDP The 1987 Constitution mandates that education receive the highest budgetary priority, apparently in reaction to declining public investment in education and a need to reverse the country's priorities from military spending to education spending. (Constitutional Commission of 1986) Yet education has not received the highest budgetary priority; servicing the public debt has.17 Under the Revised Administrative Code of 1987, payments of principal and interest on public debt are automatically appropriated. Debt service (interest payments on public debt) has consistently remained government's primary budgetary priority. "The apparent conflict between prioritising debt service over education was resolved by the Supreme Court in 1991. Petitioners assailed the constitutionality of the automatic appropriations provision of the law and asserted that the debt service appropriation in the 1990 budget violated the constitutional provision assigning the highest budgetary priority to education. The Supreme Court disagreed. While affirming the constitutional mandate, the Court decreed that Congress cannot be deprived of the 'power to respond to the imperatives of 17 70 See General Appropriations Acts, previous years.