Facts:

The case of Leticia A. Alimario vs. The Honorable Commission on Audit revolves around the retirement and subsequent financial accountability of the petitioner, Leticia A. Alimario. Alimario served the government for 43 years and retired as Section Chief of the Billing Unit, Collection Branch of the Bureau of Internal Revenue (BIR), Region No. 4-C, located in San Pablo City, on November 17, 1989, when she reached the age of 65. Upon her retirement, there was a delay in the processing of her retirement papers due to the refusal of the BIR's Accounting Division to issue her a national clearance, citing incomplete supporting documents for her monthly reports during her tenure as Acting Accountable Officer from June 1973 to May 1974.

On April 2, 1990, Carmelita S. J. Pascual, an Assistant Chief at BIR National Office, notified Alimario of outstanding balances in her subsidiary ledger for documentary stamps amounting to P 6,010.00 and for science stamps amounting to P 165,308.50.

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Facts:

Background of the Case

• The petitioner, Leticia A. Alimario, served in the government for 43 years and retired on November 17, 1989 at the age of 65.
• At the time of her retirement, she was the Section Chief of the Billing Unit, Collection Branch of the Bureau of Internal Revenue (BIR), Region No. 4-C, San Pablo City.

Problems in Retirement Processing and Record Keeping

• The processing of her retirement papers was delayed when the Accounting Division of the BIR National Office refused to issue her clearance.
• The reason for the delay was the alleged incompleteness of supporting documents in her monthly reports dating from June 4, 1973, to May 9, 1974, when she was the Acting Accountable Officer of the Administrative Branch, Revenue Region No. 9 (later re-numbered as Region 4-C).

Alleged Ledger Balances and Notification

• On April 2, 1990, Carmelita S. J. Pascual, Assistant Chief of the Revenue Accounting Division (RAD) of the BIR National Office, notified the petitioner of outstanding ledger balances.
• The balances reportedly were:
• P6,010.00 for documentary stamps.
• P165,308.50 for science stamps.
• The petitioner was advised to submit documents to offset these balances.

Documentary Evidence Submitted by the Petitioner

• A copy of Regional Travel Assignment Order No. 2-74 dated May 3, 1974, indicating her transfer to the Office of Collection Agent, and that Francisco P. Evasco would assume her former position.
• A Memorandum Receipt dated May 13, 1974, signed by Francisco P. Evasco, showing that she had submitted her working sheets on documentary and science stamps (covering May 1 to 10, 1974) along with her monthly accountability report for the period of June 1973 to April 1974.
• A clearance issued by Evasco on May 13, 1974, stating that she had no money or property accountabilities as of that date.

Deficiencies in Official Records

• The official records of the Commission on Audit (COA) in San Pablo City for the period 1970–1980, including the file of her reports and the certificate of settlement, were destroyed due to fire caused by termites in the warehouse.
• Armando A. Duran, Chief of the BIR Accountable Forms Division (AFD), certified that:
• No records of issuances for documentary and science stamps existed prior to January 1, 1974.
• The earliest monthly report from Revenue Region No. 4-C, San Pablo City was from June 1975.

Recommendations and COA Decisions

• Acting on the available certifications, BIR Deputy Commissioner Victor A. Deoferio, Jr. recommended the approval of Alimario’s request to condone or write off the unaccounted ledger balances.
• State Auditors Teresa F. Demetillo and Alipio S. Bernardo, Jr., through separate indorsements, recommended:
• Writing off the P137,601.00 unrecorded requisition of science stamps.
• Deducting the P28,010.00 representing the outstanding balance of documentary stamps from her terminal leave pay.
• The petitioner, consenting to expedite the release of her retirement pay, agreed to the deduction without waiving her right to appeal an adverse COA ruling.
• On April 3, 1991, COA rendered Decision No. 1815 adopting these recommendations, and on June 3, 1992, COA rendered Decision No. 2332 denying her motion for reconsideration.

Relief Sought and Arguments of the Petitioner

• The petitioner sought the reversal of COA Decisions Nos. 1815 and 2332 and the refund of the deducted amount of P28,010.00.
• She contended that:
• The COA’s classification of the amount as a “shortage” was baseless.
• There was no substantive evidence linking her to the unaccounted ledger balances.
• Supporting points in her favor included:
• A “clean slate” provided by her successor, Francisco P. Evasco, in 1974 after she had presented all available documents.
• A declaration by San Pablo City State Auditor Rodolfo C. Sy noting the destruction of records.
• Certification by Armando Duran confirming the absence of records prior to 1974.
• A recommendation by BIR Deputy Commissioner Victor A. Deoferio, Jr. suggesting the condonation or write-off of the unaccounted balances without separating the amounts.

Positions of the Solicitor General and the Respondent COA

• The Solicitor General supported the petition and proposed that the COA be given an opportunity to defend its decisions.
• The COA, in its comment, differentiated between “shortage” and “overage”:
• A “shortage” arises when the recorded accountability exceeds the actual on-hand amount, necessitating restitution by the accountable officer.
• An “overage” occurs when the actual amount on hand exceeds the recorded accountability, with the excess taken as government funds.
• COA maintained that the P28,010.00 in documentary stamps should be deducted from her terminal leave pay as it represented a shortage.

Issue:

• Whether the Commission on Audit erred in classifying and deducting the amount of P28,010.00 from the petitioner’s terminal leave pay as a shortage in documentary stamps.
• Whether the COA’s reliance on recommendations from State Auditors without corroborating evidence amounted to a decision not supported by substantial evidence.
• Whether the government’s failure in its record-keeping practices should preclude holding the petitioner accountable for alleged discrepancies in ledger balances.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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