Case Digest (G.R. No. 253253) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Victor M. Barroso, then President of Bukidnon State University (formerly Bukidnon State College), challenges two decisions of the Commission on Audit (COA) Proper. On March 17, 2005, Administrative Officer II Evelyn S. Mag-abo was granted a cash advance of ₱574,215.27 for the payment of BSU employees’ salaries. On March 28, 2005, Mag-abo encashed the payroll check at Landbank in Malaybalay City but was robbed of the funds en route back to BSU. COA Audit Team Leader Teresita Quijada initiated inquiry by issuing an Audit Observation Memorandum and Demand Letter. Mag-abo’s request for relief was denied by the Legal Adjudication Office and the Adjudication and Settlement Board. On appeal to the COA Proper, Decision No. 2014-015 sustained her accountability. After Mag-abo’s motion for reconsideration was denied in COA Decision No. 2015-157, the COA Proper held her, Barroso (her supervisor), and Wilma L. Gregory (BSU Chief Administrative Officer) solidarily liable under Sec Case Digest (G.R. No. 253253) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and COA Proper decisions
- Victor M. Barroso, President of Bukidnon State University (BSU), is the petitioner.
- Commission on Audit (COA) Proper issued Decision No. 2015-157 (April 6, 2015) holding him solidarily liable with two BSU officers for P 574,215.27, and Decision No. 2020-232 (January 29, 2020) denying his motion for reconsideration.
- Underlying payroll robbery and COA proceedings
- On March 17, 2005, Administrative Officer II Evelyn S. Mag-abo received a cash advance of P 574,215.27 to pay BSU salaries for March 16–31, 2005.
- On March 28, 2005, Mag-abo encashed the payroll check at Landbank Malaybalay. As she and colleagues walked back to BSU, a man snatched her bag with the money and fled on a motorcycle.
- COA Audit Team Leader issued an Audit Observation Memorandum (April 1, 2005) and Demand Letter directing Mag-abo to explain and return the shortage. Mag-abo’s relief requests were denied by the COA Legal Adjudication Office (Decision No. LAO-N-2006-132) and Adjudication and Settlement Board, and by COA Proper (Decision No. 2014-015).
- Mag-abo’s motion for reconsideration to COA Proper included a March 2014 affidavit of retired BSU Accountant Gloria P. Torres stating Mag-abo had requested, but was denied, security escort and vehicle. COA Proper denied reconsideration in Decision No. 2015-157 and, for the first time, held Barroso and BSU Chief Administrative Officer Wilma L. Gregory solidarily liable under PD 1445, Sections 102(1) and 104.
- Barroso then filed his own motion for reconsideration; COA Proper denied it in Decision No. 2020-232, ruling he was not deprived of due process and that he failed to implement adequate internal controls.
- Supreme Court petition and proceedings
- Barroso filed a petition for certiorari (Rule 64, Rules of Court), alleging grave abuse of discretion, denial of due process, and lack of evidence of his negligence.
- The Office of the Solicitor General argued for dismissal due to missing record attachments and supported COA Proper’s liability finding.
- The Supreme Court addressed procedural lapses (late filing excused) and reached the merits, finding Barroso’s administrative due process rights were violated and nullifying COA Decisions Nos. 2015-157 and 2020-232 insofar as they imposed liability on him.
Issues:
- Did the COA Proper violate Victor M. Barroso’s right to administrative due process by impleading him late, failing to furnish the evidence (Torres’ affidavit), and denying him a meaningful opportunity to be heard?
- Was there substantial evidence to support COA Proper’s finding of Barroso’s negligence and solidary liability under PD 1445, Sections 102(1) and 104?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)