Case Digest (G.R. No. 228795)
Facts:
Estelita A. Angeles v. Commission on Audit (COA) and COA‑Adjudication and Settlement Board, G.R. No. 228795 [Formerly UDK 15699], February 27, 2023, the Supreme Court En Banc, Lopez, J., writing for the Court.Petitioner Estelita A. Angeles was the officer‑in‑charge municipal treasurer of San Mateo, Rizal. On March 12, 2010, cashier Lily de Jesus and a revenue collection officer withdrew P1,300,000.00 in payroll funds from the Land Bank and, while returning in the municipal service vehicle driven by Felix Alcantara, were attacked: Felix was shot and rendered unconscious, and Lily was fatally shot after a perpetrator broke the passenger window and seized the black bag with the payroll money. Suspects Jay‑ar Magpuri and Virgilio Redito were later arrested and indicted for Robbery with Homicide.
Three days later, on March 15, 2010, Estelita informed the COA Audit Team Leader of the incident and requested relief from accountability for the lost payroll money. She explained that the municipal practice lacked a police escort for bank transactions and that personnel followed an internal travel pass procedure. The municipal mayor, the Audit Team Leader, and the Supervising Auditor recommended granting relief, citing positive identification of the culprits and no fault by Estelita.
The COA Adjudication and Settlement Board (ASB) denied the relief request on May 30, 2012, holding Estelita and Lily’s estate jointly and severally liable for P1,300,000.00 on the ground that a security escort was necessary given the amount involved. Estelita sought review before the COA; the COA denied her petition in a Decision dated April 13, 2015, affirming the ASB for finding that merely obtaining a travel pass without a security escort fell short of necessary diligence. Her motion for reconsideration was denied on June 6, 2016 for being filed out of time and for lack of merit.
Estelita filed this Petition for Certiorari under Rule 64 (in relation to Rule 65) raising, among others, that absence of a security escort did not ipso facto demonstrate negligence and that the robbery was an unforeseeable, violent event. The Office of the Solicitor General opposed, arguing COA correctly found negligence for allowing bank tran...(Pro-only)
Issues:
- Was the Petition for Certiorari timely filed under Section 3, Rule 64 of the Rules of Court?
- Did the COA commit grave abuse of discretion in denying relief from accountability by finding petitioner negligent for failing to secure a security escort when transpor...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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