the national interest and ... the attainment of other state policies or objectives.' The Court found government complied with the constitutional mandate because it had increased the budget for education since 1985. Thus the Court held: "'Having faithfully complied therewith, Congress is certainly not without any power, guided only by its good judgment, to provide an appropriation, that can reasonably service our enormous debt, the greater portion of which was inherited from the previous administration. lt is not only a matter of honor and to protect the credit standing of the country, More especially, the very survival of our economy is at stake. Thus, if in the process Congress appropriated an amount for debt service bigger than the share allocated to education, the Court finds and so holds that said appropriation cannot be thereby assailed as unconstitutional.' "Since its promulgation, this decision has not been challenged." (Diokno, 2006) On the international level, there is similarly no threshold or figure that countries should follow to realize a particular human right. The frequently cited World Health Organization (WHO) "recommendation" that countries should spend 5% of GDP on health appears to have q uestionable basis. Savedoff (2007) explains: "The WHO has produced substantial material on health care financing issues, going back to at least 1963. However, never formally adopted or published a recommendation that countries should spend 5 percent of national income on health care. The 5 percent figure first appeared in WHO documents in 1981 as an indicator that should be monitored, not as a recommended level of health spending. appears that researchers, journalists, and policymakers later transformed the figure into a recommendation. it lt "The WHO documents provide no explanation for why 5 percent of GDP was chosen for the indicator, although this amount was close to the upper bound of health spending estimates in the early 1980s. Setting a 5 percent goal sounds less ambitious today than it would have been considered at the time-both because researchers had underestimated health spending (particularly by ignoring private health spending) and because health spending was much lower." Because there is a lack of guidance, the Philippines must set its own objective benchmarks and targets to establish the financial resources needed to progressively realize human rights. This may entail mainstreaming HRBA into the Organizational Performance lndicator Framework (OPIF) and taking full advantage of recent DBM initiatives such as zero based budgeting, gender mainstreaming, and citizen participation in the budgeting process, from the perspective of human rights. OPIF is a planning and budgeting tool that "seeks to align goods and services supported by the budget ... with the desired outcomes that government aims to achieve or influence. lt requires the specification and reporting of objective and measurable performance indicators to show the extent to which a departmenVagency's major final outputs (MFOs) influence desired outcomes identified in the national development plan." (DBM, 2012) Key to OPIF are: (a) an agreement of outputs that a government agency delivers together with their expected contribution to the achievement of outcomes and goals; (b) choice of clear 71