Case Digest (G.R. No. 278582)
Facts:
Ma. Gladys Cruz-Sta. Rita, Lorna T. Dy, Alexander P. Japon, Marina del Rosario, Monica R. Legaspi, Marciana B. Guinto, and National Power Corporation Recipient-Beneficiaries v. Commission on Audit, G.R. No. 278582, April 22, 2025, the Supreme Court En Banc, Lazaro-Javier, J., writing for the Court. The petition challenges COA dispositions that disallowed payments of Group Hospitalization and Life Insurance Plan (GHLIP) premiums and held certain NPC officers and employee-beneficiaries liable.On July 21, 2015, an Audit Team Leader and a Supervising Auditor issued Notice of Disallowance (ND) No. NPC-15-008(14) for PHP 34,047,188.03 covering GHLIP premium payments for April 1, 2014 to March 31, 2015. The ND said the payments violated Section 28(b) of Commonwealth Act No. 186 (as amended by Republic Act No. 4968), COA Resolution No. 2005-001, and could not be charged against DBM Budget Circular No. 2013-4’s 30% MOOE savings allocation. The ND named NPC officials (including petitioners Cruz-Sta. Rita, Dy, Japon, Legaspi, Del Rosario, and Guinto) and the payee-employees as liable for return.
The NPC officers appealed to the COA Corporate Government Sector-Cluster 3, which, by Decision dated June 27, 2016 (Director Rufina S. Laquindanum), denied the appeal and affirmed the ND, treating the premiums as additional compensation contrary to COA policy. The petitioners sought further review before the COA En Banc; by Decision dated January 24, 2022 the COA En Banc denied the petition for review and affirmed the disallowance and the liability of certain officers, citing Republic Act No. 6758 (Salary Standardization Law), COA Circular No. 2012-003, and directing verification for possible supplemental ND against Board members and LMCC participants. The COA then denied the petitioners’ motion for reconsideration on December 7, 2023.
Cruz-Sta. Rita et al. filed this Petition for Certiorari under Rule 64 in relation to Rule 65 of the Rules of Court, alleging grave abuse of discretion: (a) NPC is not covered by the Salary Standardization Law because of Republic Act No. 7648 (EPCA) and Memorandum Order No. 198; (b) the GHLIP payments were legitimately part of DBM Circular No....(Pro-only)
Issues:
- Was the issuance of ND No. NPC-15-008(14) on the payments of GHLIP premiums proper?
- Are the certifying and approving officers of the NPC liable to return the amounts paid as GHLIP premiums?
- Are the passive-recipients or beneficiaries of the GHLIP premiums liable to return the amounts corresponding to ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)