Case Digest (G.R. No. 198457)
Facts:
- Petitioners: Filomena G. Delos Santos, Josefa A. Bacaltos, Nelanie A. Antoni, and Maureen A. Bien.
- Respondent: Commission on Audit (CoA).
- Dispute: Disallowance of P3,386,697.10 for anti-rabies drugs under the Tony N' Tommy (TNT) Health Program.
- Funding: Priority Development Assistance Fund (PDAF) of Congressman Antonio V. Cuenco, Second District of Cebu City.
- Allocation: Funds appropriated to Vicente Sotto Memorial Medical Center (VSMMC) via a Memorandum of Agreement (MOA) in October 2001.
- Allegations: Forgery and falsification of prescriptions and documents for the TNT Program.
- Investigation: Conducted by Delos Santos, the Medical Center Chief, followed by a CoA audit.
- Findings: Multiple irregularities, including falsified prescriptions and fictitious patients.
- Notice of Disallowance: ND No. 2008-09-01 issued on September 8, 2008.
- CoA Decision: Petitioners held solidarily liable for the disallowed amount.
- Appeals: CoA affirmed the disallowance in Decision Nos. 2010-051 and 2011-045.
- Legal Action: Petitioners filed a petition for certiorari under Rule 64 in relation to Rule 65 of the Rules of Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed the petition.
- Upheld CoA's decisions holding petitioners solidarily liable for the disallowed amount.
- Referred the case to the Office of the Ombudsman for investigation and possi...(Unlock)
Ratio:
- No grave abuse of discretion by CoA in issuing the decisions.
- CoA's findings based on substantial evidence, including VSMMC officials' failure to adhere to auditing laws, rules, and regulations.
- Emphasis on public officers' liability for ensuring government funds are expended lawfully.
- Petitioners' neglect facilitated validation and payment of 133 falsified prescriptions and fictitious claims.
- Good faith defense not applicable due to violat...continue reading
Case Digest (G.R. No. 198457)
Facts:
The case of "Delos Santos v. Commission on Audit" involves petitioners Filomena G. Delos Santos, Josefa A. Bacaltos, Nelanie A. Antoni, and Maureen A. Bien against the respondent Commission on Audit (CoA). The dispute arose from the disallowance of funds amounting to P3,386,697.10 for the purchase of anti-rabies drugs under the Tony N' Tommy (TNT) Health Program, which was funded by the Priority Development Assistance Fund (PDAF) of then Congressman Antonio V. Cuenco of the Second District of Cebu City. The funds were appropriated to the Vicente Sotto Memorial Medical Center (VSMMC) through a Memorandum of Agreement (MOA) signed in October 2001. Allegations of forgery and falsification of prescriptions and documents for the availment of medicines under the TNT Program surfaced, prompting an investigation by Delos Santos, the Medical Center Chief, and a subsequent audit by the CoA. The audit revealed multiple irregularities, including falsified prescriptions and fictitious patients, leading to the issuance of Notice of Disallowance (ND) No. 2008-09-01 on September 8, 2008. The CoA held the petitioners solidarily liable for the disallowed amount. The petitioners appealed the ...