Case Digest (G.R. No. 179267) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dadole et al. v. Commission on Audit, the petitioners are Hon. RTC Judges Mercedes G. Dadole (Executive Judge, Branch 28), Ulric R. Caaete (Presiding Judge, Branch 25), Agustin R. Vestil (Presiding Judge, Branch 56), and Hon. MTC Judges Temistocles M. Boholst (Presiding Judge, Branch 1), Vicente C. Fanilag (Judge Designate, Branch 2), and Wilfredo A. Dagatan (Presiding Judge, Branch 3), all of Mandaue City. Beginning in 1986, they received monthly allowances of ₱1,260 under a Sangguniang Panlungsod appropriation ordinance, increased to ₱1,500 in 1991. On March 15, 1994, the Department of Budget and Management (DBM) issued Local Budget Circular No. 55, capping additional allowances at ₱1,000 per month for judges in cities. Acting on this, the Mandaue City Auditor reduced the petitioners’ allowances to ₱1,000 as of October 1994 and demanded reimbursement for the April–September excess. The judges protested before the City Auditor, who considered it a motion for reconsideration Case Digest (G.R. No. 179267) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Allowances Background
- Since 1986, the Regional Trial Court (RTC) and Municipal Trial Court (MTC) judges in Mandaue City received ₱1,260 monthly allowances, increased by city ordinance to ₱1,500 in 1991.
- These allowances were charged to the city’s yearly appropriation ordinance under Section 458(a)(1)(xi) of R.A. 7160 (Local Government Code).
- Issuance and Implementation of DBM Local Budget Circular No. 55 (LBC 55)
- On March 15, 1994, the Department of Budget and Management (DBM) issued LBC 55 capping additional allowances at ₱1,000 for cities and ₱700 for municipalities, effective immediately without publication.
- The City Auditor of Mandaue enforced LBC 55 by reducing each judge’s allowance to ₱1,000 from October 1994 and demanding reimbursement of excess amounts paid from April to September 1994.
- Administrative Proceedings
- The petitioner judges protested to the City Auditor, whose office forwarded the matter as a “motion for reconsideration” to the Commission on Audit (COA).
- On September 21, 1995, COA denied the reconsideration (Decision No. 95-568), and on May 28, 1996, it denied the petitioners’ motion for reconsideration (Resolution No. 96-282).
- Petition for Certiorari
- The judges filed a Rule 64 petition in the Supreme Court to annul the COA decision and resolution, raising questions on:
- The statutory and constitutional basis for city-granted allowances to judges.
- The authority of an administrative circular to limit local legislative power.
- The proper interpretation of LBC 55 as applied to the judiciary.
- The validity of LBC 55 given its non-publication.
Issues:
- Has Mandaue City the statutory and constitutional authority to grant additional allowances to judges?
- Can an administrative circular like LBC 55 override the power of a city legislative body by fixing allowance ceilings?
- Did COA correctly interpret LBC 55 to include judges and cap their allowances at ₱1,000 despite a long-standing ₱1,500 rate?
- Is LBC 55 valid and enforceable despite not being duly published?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)