G.R. No. 262193 - Development Bank of the Philippines vs. Commission on Audit

The Development Bank of the Philippines (DBP) issued Circular No. 10 on March 7, 2005, amending the method of computing the money value of leave credits (MVLC) for its officials and employees.
The amended provision changed the base of computation from the "highest monthly salary received" to the "gross monthly cash compensation," which included basic salary plus various allowances and longevity pay.
The Commission on Audit (COA) Corporate Auditor (CA) issued an Audit Observation Memorandum (AOM) on July 31, 2006, asserting that DBP's computation based on gross monthly cash compensation was contrary to existing laws, specifically CSC Circular No. 41 (1998) and Presidential Decree No. 1146.

Notices of Disallowance (NDs) were issued on February 28 and July 4, 2007, disallowing payments of MVLC computed using gross monthly cash compensation, amounting to ~P26.18 million.
DBP's motion for reconsideration was denied by the Supervising Auditor on May 15, 2007, citing lack of requisite authority or approval of Office of the President and Department of Budget and Management (DBM).
DBP filed appeals and memoranda challenging the NDs and citing Section 13 of DBP Revised Charter, which empowered the DBP Board of Directors (BOD) to fix remunerations and exempts the bank from certain existing compensation laws.

LSS affirmed the NDs in 2009, holding approving officials jointly and severally liable to refund excess payments.
DBP argued the COA violated due process and referenced President Gloria Macapagal Arroyo's (PGMA) approval of its Compensation Plan, contending it legitimized Circular No. 10 and related remuneration schemes.
COA Commission Proper (CP) Decision No. 2018-197 affirmed NDs but modified them, exempting passive recipients from refunding amounts received in good faith.
The CP also denied DBP’s motion for reconsideration in Decision No. 2022-072, modifying the ruling to require all recipients, including passive ones, to refund disallowed benefits.

DBP filed a petition for certiorari seeking to nullify the COA decisions.
DBP claimed COA violated due process and right to speedy disposition of cases due to extreme delays.
It argued the 2021 DBP case recognizing PGMA's approval of the Compensation Plan operates as res judicata.
DBP maintained that its BOD has authority to define gross monthly compensation and that the COA wrongly disallowed the payments.

COA Legal Services Sector maintained DBP Circular No. 10 conflicted with laws and COA rules, disallowing computation of MVLC based on gross compensation.
COA argued PGMA's post facto approval was invalid as it violated the Omnibus Election Code prohibition of salary increases within 45 days before elections.
COA asserted no violation of due process and that the delays were caused by organizational adjustments.
It held that DBP officials approving the payments and recipients are liable to refund disallowed amounts.

Whether DBP was denied due process.
Whether DBP's right to speedy disposition of cases was violated.
Whether the 2021 DBP case operates as res judicata on the present petition.
Whether DBP may legally define gross monthly compensation for MVLC computation.
Whether DBP officials and employees involved in approval/certification and receipt of disallowed MVLC are liable to refund.