Facts:

The case involves Estelita A. Angeles, the petitioner, against the Commission on Audit (COA) and the COA Adjudication and Settlement Board, the respondents. The events leading to the case began on March 12, 2010, at approximately 2:30 p.m. Cashier Lily De Jesus (De Jesus) and revenue collection officer Estrellita Ramos (Ramos), both from the Office of the Treasurer of the Municipality of San Mateo, Rizal, embarked on a trip to the Land Bank of the Philippines in Marikina City to withdraw ₱1,300,000.00 meant for payroll. They were accompanied by municipal driver Felix Alcantara (Alcantara). Upon their return at around 4:30 p.m., while stopped at a traffic light on J.P. Rizal St., two men approached—they shot Alcantara and then forcibly took the payroll money from De Jesus. The robbery ended tragically with De Jesus being shot fatally.

After the incident, the municipal treasurer-in-charge, Estelita Angeles, reported it to the Audit Team Leader on March 15, 2010, and filed a reques

...

Facts:

The Bank Transaction and Robbery Incident

• On March 12, 2010, cashier Lily De Jesus and revenue collection officer Estrellita Ramos, together with municipal driver Felix Alcantara, conducted a bank withdrawal of P1,300,000.00 at the Land Bank of the Philippines.
• After completing the transaction and returning to their office, while passing a traffic light on J.P. Rizal Street in Marikina City, an unknown assailant fired a gunshot that wounded Felix Alcantara, eventually causing him to lose consciousness.
• A second assailant broke the vehicle’s passenger-side window, forcibly taking a black bag containing the payroll money and subsequently shooting Lily de Jesus, which resulted in her death.
• Following the investigation, suspects Jay-ar Magpuri and Virgilio Redito were arrested and indicted for robbery with homicide.

The Request for Relief from Accountability

• On March 15, 2010, Estelita Angeles, the officer-in-charge municipal treasurer, reported the incident to the Audit Team Leader and requested relief from accountability for the lost payroll funds.
• In her submission, Estelita explained that she took over the position on October 27, 2008, and noted that previous paymasters or cashiers transacted with the bank without a security escort, following the standard operating procedure requiring only a travel pass.
• Both the municipal mayor, Jose Rafael Diaz, and the Audit Team Leader recommended the grant of relief, citing positive identification of the culprits and the absence of any fault or participation by Estelita in the robbery.
• Despite these recommendations, on May 30, 2012, the Adjudication and Settlement Board denied the request for relief and found Estelita Angeles and the estate of the late Lily de Jesus jointly and severally liable for the payroll money, emphasizing that the absence of a security escort, given the amount involved, facilitated the robbery.

Subsequent Appeals and COA Decision

• Estelita elevated the case to the Commission on Audit (COA) arguing that her due diligence was evident based on established practice and that a security escort might have increased the risk by drawing extra attention.
• On April 13, 2015, the COA denied her petition on the ground that withdrawing P1,300,000.00 without a security escort did not meet the higher degree of precaution required.
• Estelita sought reconsideration of the COA’s decision; however, on June 6, 2016, the COA denied the motion for reconsideration for being filed out of time and lacking merit.
• Subsequently, Estelita filed a Petition for Certiorari under Rule 64, challenging the COA’s denial of relief from accountability, while contending that the robbery was an unforeseeable, fortuitous event despite the absence of a security escort.
• The Office of the Solicitor General (OSG) argued that the absence of a security escort demonstrated negligence and that the COA had properly considered the precautions expected of an accountable officer handling government funds.

Issue:

Procedural Timeliness and the Reglementary Period

• Whether Estelita’s Petition for Certiorari was filed in a timely manner within the 30-day reglementary period pursuant to Section 3, Rule 64 of the Rules of Court.
• Whether her failure to provide a complete statement of material dates (notification of the COA decision, filing of her motion for reconsideration, and the notice of its denial) affects the timeliness of the petition.

Standard of Due Diligence and Negligence in Handling Public Funds

• Whether the practice of transacting bank withdrawals with only a travel pass, and without securing a security escort, constitutes negligence on the part of the accountable municipal officers.
• Whether the absence of a security escort is sufficient to hold Estelita and the late Lily de Jesus accountable for the full amount of the payroll money.

Application of Substantial Justice Versus Strict Procedural Rules

• Whether a rigid application of the procedural time limits is justified in light of the circumstances surrounding the robbery.
• Whether the need to avoid grave injustice warrants a liberal interpretation of the rules such that relief from accountability should be granted despite procedural defects.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)