Case Digest (G.R. No. 92585) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Caltex Philippines, Inc. v. Commission on Audit, G.R. No. 92585 decided on May 8, 1992, petitioner Caltex Philippines, Inc. challenged the authority of the Commission on Audit (COA) and Commissioners Bartolome C. Fernandez and Alberto P. Cruz for disallowing its claims against the Oil Price Stabilization Fund (OPSF) and for dictating the method of remittance and offset of collections. Under Section 8 of Presidential Decree No. 1956, as amended by Executive Order No. 137, the OPSF was created to stabilize domestic fuel prices by reimbursing oil companies for cost increases from exchange–rate adjustments and for underrecovery due to mandated price reductions. Between February and March 1989, COA directed Caltex to remit unremitted additional tax collections from 1986–1988, held its reimbursement claims in abeyance, and prohibited further offsetting. Caltex proposed a simultaneous remittance–reimbursement arrangement, which COA partly accepted in Decision No. 921 (June 7, 1989), Case Digest (G.R. No. 92585) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Caltex Philippines, Inc. (CPI) seeks review under Rule 65 of the Rules of Court (certiorari) of Commission on Audit (COA) decisions disallowing CPI’s claims for reimbursement from the Oil Price Stabilization Fund (OPSF) and preventing offset of remittances against reimbursements.
- COA, by letters dated February 2, 1989 and March 9, 1989, directed CPI to remit unpaid OPSF collections (totaling over ₱1.28 billion for 1986–1988) and held its reimbursement claims in abeyance, also prohibiting further offsetting.
- OPSF Framework
- Created under Section 8, Presidential Decree No. 1956 (as amended by E.O. 137):
- Sources of funding include ad valorem/customs tax increases, lifting tax exemptions, additional imposts, and peso cost differentials.
- Uses include reimbursement for (1) cost increases due to exchange‐rate/world‐price changes and (2) cost underrecovery from mandated domestic price reductions. Underrecovery “includes” reduction in company take, internal ad valorem tax cuts, and “other factors” determined by the Department of Finance.
- COA pre-audit and subsequent Decision No. 921 (June 7, 1989) accepted CPI’s proposal for simultaneous remittance and reimbursement, subject to retention and no further offsets. Decision No. 1171 (February 16, 1990) later disallowed financing charges, inventory losses, and sales to Atlas/Marcopper, but allowed export sales reimbursements.
- Procedural History
- CPI filed the present petition on March 28, 1990, assigning errors to COA’s disallowances (financing charges, NPC sales, Atlas/Marcopper sales), prohibition on offsets, and disallowance of pending claims.
- COA and Commissioners filed comment (September 6, 1990); Supreme Court gave due course (May 30, 1991) and resolved memoranda by petitioner (August 14, 1991) and respondents (September 6, 1990).
Issues:
- Whether COA validly disallowed CPI’s recovery of financing charges from the OPSF.
- Whether CPI’s underrecovery claim on sales to the National Power Corporation (NPC) is reimbursable.
- Whether CPI may recover reimbursements on sales to Atlas Consolidated Mining & Development Corporation and Marcopper Mining Corporation.
- Whether CPI may offset its OPSF remittances against its reimbursement claims.
- Whether COA properly disallowed CPI’s claims pending resolution at the Office of Energy Affairs (OEA) and Department of Finance (DOF).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)