Case Digest (G.R. No. 254394)
Facts:
In Libertad O. Alameda, D.M.D., et al. v. Commission on Audit, petitioners Libertad O. Alameda (Municipal Mayor of San Agustin, Surigao del Sur), Maria Lourdes A. Navaja (Municipal Accountant, retired), and Rosenda D. Lamela (Municipal Budget Officer) challenged Commission on Audit (COA) Decision No. 2018-350 dated October 3, 2018 and Resolution No. 2020-291 dated January 31, 2020. On January 26, 2015, COA Team 2-LGS issued Notice of Disallowance No. 15-001-101-(13&14) for ₱1,248,085.69 covering salaries, benefits, and operating expenses paid to Dr. Edmund L. Lamela as Municipal Health Officer from September 12, 2013 (the expiration of his 12-month temporary appointment) to December 31, 2014. COA Regional Office No. XIII affirmed the disallowance on December 14, 2015, finding no valid appointment or color of authority after September 11, 2013, but granted Dr. Lamela quantum meruit compensation while holding petitioners liable for lack of due diligence. Upon automatic review, COACase Digest (G.R. No. 254394)
Facts:
- Background and Appointment
- On 11 September 2012, Dr. Edmund L. Lamela was appointed Municipal Health Officer (MHO) of San Agustin, Surigao del Sur under a temporary 12-month appointment pursuant to Executive Order No. 292.
- In the 2013 elections, Libertad O. Alameda became Municipal Mayor; Dr. Lamela continued to perform MHO duties thereafter.
- Notice of Disallowance and COA Proceedings
- On 26 January 2015, the COA Team 2 issued Notice of Disallowance No. 15-001-101-(13&14) disallowing P 1,248,085.69 representing Dr. Lamela’s salaries, benefits, and MOOE from 12 September 2013 to 31 December 2014, and named Mayor Alameda, Municipal Accountant Navaja, Budget Officer Lamela, Municipal Treasurer Orcullo, Dr. Lamela, and HRMO Salinas as liable.
- Petitioners appealed to COA Regional Office No. XIII, which on 14 December 2015 affirmed the disallowance, held petitioners Alameda, Navaja, Lamela and Salinas liable for negligence, applied quantum meruit to compensate Dr. Lamela, and absolved Orcullo.
- On automatic review, COA en banc Decision No. 2018-350 (3 October 2018) approved the regional decision but modified it to exempt Dr. Lamela and Orcullo from liability.
- COA en banc Resolution No. 2020-291 (31 January 2020) denied petitioners’ motion for reconsideration.
- Petition to the Supreme Court
- Petitioners filed a Rule 64/65 petition for certiorari with prayer for injunctive relief before the Supreme Court, claiming grave abuse of discretion by the COA.
- The OSG initially sought an extension then filed a manifestation supporting petitioners’ positions; the COA’s PLO later filed a consolidated comment defending the COA issuances.
Issues:
- Did the COA commit grave abuse by declaring material dates without basis in law or fact, violating petitioners’ due process rights?
- Did the COA err in declaring that Dr. Lamela was not a de facto officer, absent legal basis or substantial evidence, in violation of due process?
- Did the COA err in awarding Dr. Lamela compensation solely on equity grounds without recognizing his de facto officership, contrary to law and unsupported by evidence?
- Did the COA err in ordering petitioners to refund the disallowed amount without factual or legal basis, violating due process?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)