Case Digest (G.R. No. 213525) Core Legal Reasoning Model
Facts:
In the case entitled Fortune Life Insurance Company, Inc. v. Commission on Audit (COA) Proper et al., petitioner Fortune Life Insurance Company, Inc. entered into a memorandum of agreement with the Provincial Government of Antique (LGU) for the life insurance coverage of qualified barangay officials, obligating an amount of P4,393,593.60 as premium payment. The LGU submitted the disbursement voucher to the Commission on Audit – Antique Office (COA-Antique) for pre-audit, which disallowed the payment, citing lack of legal basis under Republic Act No. 7160 (Local Government Code). Following the denial of its appeal to the COA, petitioner filed a money claim with COA. On November 15, 2012, COA denied the petition based on Sections 447 and 458 of the Local Government Code, ruling that only municipal or city governments have the power to secure group insurance for barangay workers, and also highlighted lack of publication compliance under Republic Act No. 9184 (Government Procuremen
...
Case Digest (G.R. No. 213525) Expanded Legal Reasoning Model
Facts:
- Execution of Memorandum of Agreement and Premium Payment
- Fortune Life Insurance Company, Inc. (petitioner) and the Provincial Government of Antique (LGU) entered into a memorandum of agreement to provide life insurance coverage to qualified barangay secretaries, treasurers, and tanods.
- The LGU obligated the amount of P4,393,593.60 as premium payment and submitted the disbursement voucher to COA-Antique for pre-audit.
- Disallowance of Payment and Appeal by LGU
- The COA-Antique disallowed the payment citing lack of legal basis under Republic Act No. 7160 (Local Government Code).
- The LGU filed an appeal, which was subsequently denied.
- Petition for Money Claim Before COA
- The petitioner filed a petition for money claim with COA.
- On November 15, 2012, COA issued a decision denying the petition, holding that only municipal or city governments have power to secure group insurance for barangay workers under Sections 447 and 458 of the Local Government Code.
- COA also noted LGU's failure to comply with publication requirements under Section 21 of Republic Act No. 9184 (Government Procurement Reform Act).
- Motion for Reconsideration and Denial
- The petitioner received a copy of the COA decision on December 14, 2012.
- It filed a motion for reconsideration on January 14, 2013.
- COA denied the motion, and the petitioner received the denial on July 14, 2014.
- Filing of Petition for Certiorari and Dismissal
- The petitioner filed a petition for certiorari on August 12, 2014.
- The Court dismissed the petition on August 19, 2014, for:
- Late filing of the petition.
- Non-submission of proper proof of service and lack of verified declaration.
- Failure to show grave abuse of discretion on the part of the respondents.
Issues:
- Whether the petitioner complied with the requirements for filing a petition for certiorari, particularly concerning timeliness, proof of service, and submission of verified declaration.
- Whether the “fresh period” rule as enunciated in Neypes v. Court of Appeals applies to the filing of a petition for certiorari under Rule 64 of the Rules of Court.
- Whether petitioner showed or proved the existence of grave abuse of discretion on the part of the Commission on Audit in denying the claim.
- Whether the petitioner and its counsel’s language constituted disrespect and contempt towards the Court and its Members.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)