Title
Alameda vs. Commission on Audit
Case
G.R. No. 254394
Decision Date
Apr 5, 2022
Dr. Lamela, appointed as MHO, served in good faith despite a disputed temporary appointment. COA disallowed his salaries, but SC ruled him a *de facto* officer, lifting the disallowance, citing no government loss and petitioners' good faith.
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Case Digest (G.R. No. 254394)

Facts:

  1. Appointment of Dr. Lamela: Dr. Edmund L. Lamela was appointed as Municipal Health Officer (MHO) of San Agustin, Surigao del Sur, on 11 September 2012, under a temporary appointment valid for 12 months.
  2. Election of Mayor Alameda: Libertad O. Alameda was elected as the new municipal mayor during the 2013 elections.
  3. Notice of Disallowance (ND): On 13 February 2015, COA issued an ND dated 26 January 2015, disallowing P1,248,085.69 paid to Dr. Lamela as salaries and benefits from 12 September 2013 to 31 December 2014, citing lack of a valid appointment.
  4. Identified Liable Officials: Mayor Alameda, Municipal Accountant Maria Lourdes A. Navaja, Municipal Budget Officer Rosenda D. Lamela, HRMO Designate Abundia P. Salinas, and Municipal Treasurer Julia R. Orcullo were held liable for approving or certifying the payments.
  5. Petitioners' Defense: Petitioners argued Dr. Lamela performed his duties in good faith and benefited the municipality, claiming he acted as a de facto officer. They also contended they believed his appointment was permanent.

Issue:

  1. Whether the COA committed grave abuse of discretion by:
    • Declaring the material dates of the case without legal basis.
    • Holding that Dr. Lamela was not a de facto officer.
    • Concluding Dr. Lamela was entitled to compensation based on equity but not as a de facto officer.
    • Ordering petitioners to refund the disallowed amount without factual or legal basis.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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