Case Digest (G.R. No. 147402) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Engr. Ranulfo C. Feliciano, in his capacity as General Manager of the Leyte Metropolitan Water District (LMWD), filed a petition for certiorari under Rule 64 of the 1997 Rules of Court seeking to annul the Commission on Audit (COA) Resolution of January 3, 2000 and its subsequent Decision of January 30, 2001 denying his Motion for Reconsideration. A Special Audit Team from COA Region VIII had conducted a post-audit of LMWD’s accounts and, on July 19, 1999, demanded payment of auditing fees. On October 12, 1999, Feliciano replied that LMWD could not remit such fees, citing Sections 6 and 20 of Presidential Decree No. 198 (as amended) and Section 18 of Republic Act No. 6758. He later requested a refund of all fees previously paid. The COA Chairman denied both requests, and the COA en banc upheld that denial on January 30, 2001. On March 13, 2001, Feliciano elevated the matter to this Court, attaching resolutions from the Visayas Association of Water Districts and the Philippine As Case Digest (G.R. No. 147402) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Engr. Ranulfo C. Feliciano, in his capacity as General Manager of the Leyte Metropolitan Water District (LMWD), filed a petition for certiorari under Rule 64 of the 1997 Revised Rules of Court.
- He sought to annul:
- The Commission on Audit (COA) Resolution dated January 3, 2000 denying his request to cease all audit services and stop charging auditing fees to LMWD.
- The COA Decision dated January 30, 2001 denying his Motion for Reconsideration.
- Antecedent Facts
- A Special Audit Team from COA Regional Office No. VIII conducted an audit of LMWD’s accounts.
- On July 19, 1999, COA demanded payment of auditing fees from LMWD.
- On October 12, 1999, petitioner replied, refusing payment, citing:
- Sections 6 and 20 of Presidential Decree (PD) 198, as amended.
- Section 18 of Republic Act (RA) 6758.
- On October 19, 1999, petitioner formally requested refund of all auditing fees LMWD previously paid.
- COA Chairman Gangan issued the adverse Resolution on January 3, 2000; the Motion for Reconsideration was denied on January 30, 2001.
- On March 13, 2001, petitioner filed the instant petition, bolstered by resolutions from the Visayas Association of Water Districts (VAWD) and the Philippine Association of Water Districts (PAWD).
Issues:
- Whether a Local Water District (LWD) created under PD 198, as amended, is a government-owned or controlled corporation (GOCC) with an original charter, thus subject to COA’s audit jurisdiction.
- Whether Section 20 of PD 198 prohibits COA auditors from auditing LWDs.
- Whether Section 18 of RA 6758 prohibits COA from charging auditing fees to GOCCs such as LWDs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)