Facts:

This case revolves around a petition for mandamus filed by five former police officers of the municipality of Taal, Batangas: Jose Baldivia, Marcelo Capuno, Carlito Catapang, Eliseo Dimaculangan, and Ricardo Bathan, against Flaviano Lota, the mayor of Taal. Following the November 1955 elections, the petitioners resigned from their positions, primarily because they belonged to a political faction opposing that of the respondent. They sought to compel Lota to approve vouchers for payment of their accrued leave pay upon leaving the service. The petitioners were able to secure a note from Assistant Executive Secretary Enrique C. Quema, urging the provincial treasurer to assist in the payment of their accumulated vacation and sick leave. Prior partial payments were made to them; however, they claimed that substantial amounts were still due, specifically 3.5 months for Baldivia and four months for each of the others, at a monthly rate of P35. The municipal treasurer prepared the corre

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Facts:

Background of the Case

• Petitioners, former members of the Taal, Batangas police force, resigned shortly after the November 1955 elections.
• They filed a petition for mandamus seeking to compel the respondent, Flaviano Lota (Municipal Mayor), to approve vouchers for the payment of their accumulated leave pay due upon separation from service.
• Their claim arose from a disputed unpaid balance: after receiving partial payments (one or two months’ leave pay, depending on the petitioner), they contended that they were still owed additional vacation leave pay (three and one-half months for one petitioner and four months for the others) at a rate of P35.00 per month.

Procedural and Evidentiary Background

• The petitioners had secured support from higher authorities in the form of a note issued by Assistant Executive Secretary Enrique C. Quema directed to the Provincial Treasurer of Batangas, urging assistance to secure payment for their leave pay.
• Acting on this note, the Provincial Treasurer interceded by sending letters to both the municipal mayor and treasurer of Taal, suggesting methods for effecting the payment.
• A voucher, prepared by the municipal treasurer for the additional one-month leave pay for each petitioner, was submitted for the mayor’s approval, which was subsequently refused by the respondent.

Reasons Adduced by the Respondent

• The respondent argued that there was no valid appropriation, as the municipal council had not approved the necessary budget or supplementary allotment for the claimed leave pay.
• He further contended that the petitioners held their positions illegally since their appointments as temporary employees exceeded the prescribed duration and were made without the municipal council’s consent, as required by sections 2199 and 2200 of the Revised Administrative Code.
• The municipal government’s financial constraints were also cited; heavy indebtedness and pressing obligations were given as reasons for not setting aside funds for the petitioners’ claims.

Lower Court Findings

• The lower court observed that the municipal council had not appropriated funds for the payment of the leave pay claimed by the petitioners, even though previous disbursements had been made under a duly approved supplementary budget.
• Testimony by the municipal treasurer confirmed that while the financial status of the municipality might have permitted such payment, the legal basis (i.e., the appropriations ordinance) was lacking.
• The court acknowledged the petitioners’ precarious situation and expressed sympathy while ultimately upholding the legal principle that no voucher may be approved without an authorized budget.

Observations on Public Administration

• The lower court noted the partisan nature of the dispute, highlighting that political factionalism had influenced the respondent’s conduct.
• It was observed that the respondent had expended considerable funds and effort in researching legal justifications to deny the petitioners’ claims rather than seeking a lawful means to address their valid entitlements.
• The court emphasized that the proper procedure for disbursement of municipal funds—aligned with both fiscal responsibility and constitutional mandates—had not been followed.

Issue:

Mandamus as a Remedy

• Whether a petition for mandamus can compel the municipal mayor to approve vouchers for payment of leave pay in the absence of an appropriate budget appropriation.

Constitutional and Statutory Compliance

• Whether the constitutional provision that "no money shall be paid out of the Treasury except in pursuance of an appropriation made by law" precludes the approval of vouchers without a duly enacted appropriation ordinance by the municipal council.

Legality of Appointments and Fiscal Validity

• Whether the alleged irregularity in the appointment of petitioners as temporary employees affects their rightful claim to leave pay.
• Whether such claims can override the strict fiscal requirement of having an approved budget.

Role of Municipal Authorities

• The extent to which the municipal mayor has the discretion to approve disbursements in the absence of a prescribed budget.
• The proper application of administrative law principles in the context of local governance and fiscal management.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)