Case Digest (G.R. No. 218040) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The Commission on Audit, Atty. Eleanor V. Echano, Felizardo B. Toquero, Jr., Tita B. Embestro, Susie S. Laureano, Johanson V. Disuanco, and Adela A. Tabuzo v. Hon. Erwin Virgilio R. Ferrer and Luis Raymund F. Villafuerte, Jr. (G.R. No. 218870, November 24, 2020), the petitioners are provincial auditors of Camarines Sur who, upon conducting a post-audit of provincial disbursements for Governor Luis Raymund F. Villafuerte, Jr. covering 2006 to 2010, issued ten Notices of Disallowance (NDs) for alleged violations of procurement and auditing rules. When Villafuerte did not challenge these NDs administratively, Notices of Finality of Decision (NFDs) were issued. On October 15, 2014, the former governor filed Special Civil Action Nos. P-155-2014 and P-156-2014 for certiorari and prohibition with prayer for TRO and preliminary injunction before Branch 33 of the Regional Trial Court (RTC) in Pili, Camarines Sur, then presided by Judge Marvel C. Clavecilla. The RTC granted a 72-hour T Case Digest (G.R. No. 218040) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioners: The Commission on Audit (COA) and its provincial auditors for Camarines Sur—Atty. Eleanor V. Echano (ATL), Tita B. Embestro (SA), Felizardo B. Toquero Jr., Susie S. Laureano, Johanson V. Disuanco, and Adela A. Tabuzo.
- Respondents: Hon. Erwin Virgilio R. Ferrer (Acting Presiding Judge, RTC Branch 33, Pili, Camarines Sur) and Luis Raymund F. Villafuerte Jr. (former Governor of Camarines Sur).
- Administrative Audit and Disallowances
- During his 2006–2010 term, private respondent approved disbursements for projects (conceptual designs, promotional services, security, petty cash, mobilization fees for roads and school buildings, etc.).
- COA auditors Echano and Embestro issued 10 Notices of Disallowance (NDs) between November and December 2012, citing violations of RA 9184 and COA Circular 2012-003, totaling Php 23,408,059.37.
- Finality and Trial-Court Petitions
- Private respondent did not appeal the NDs to the COA Commission Proper; Notices of Finality of Decision (NFDs) were then issued by Toquero and Laureano.
- On 15 October 2014, private respondent filed two petitions for certiorari and prohibition (Special Civil Actions P-155-2014 & P-156-2014) with RTC Branch 33, assailing the NFDs and seeking TRO/preliminary injunction.
- RTC Branch 33 issued a 72-hour TRO (20 Oct 2014), extended to 9 Nov 2014, then granted a preliminary injunction (7 Nov 2014) enjoining execution of the NDs.
- Petitioners moved to dismiss for lack of jurisdiction and failure to exhaust administrative remedies (17 Nov 2014); RTC denied the motion in orders of 18 Dec 2014 and 6 May 2015.
- Petition to the Supreme Court
- Petitioners filed a petition for certiorari and prohibition with prayer to quash the RTC orders of 18 December 2014 and 6 May 2015 (G.R. No. 218870).
Issues:
- Did the RTC commit grave abuse of discretion in assuming jurisdiction over petitions for certiorari and prohibition against COA’s provincial auditors?
- Did private respondent fail to exhaust administrative remedies before the COA Commission Proper, rendering the NDs final and executory?
- Are any exceptions to the doctrine of primary jurisdiction applicable to justify direct recourse to the RTC?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)