G.R. No. 96296 - Dizon vs. Court of Appeals

Petitioner Efraim C. Genuino was the former Chairman of the Board and CEO of PAGCOR.
Petitioner Rene C. Figueroa was formerly the Senior Vice President (SVP) of PAGCOR.
Both parties were respondents in administrative actions initiated by the Commission on Audit (COA).
Two consolidated cases before the Supreme Court: G.R. No. 230818 (Genuino v. COA) and G.R. No. 244540 (Figueroa v. COA).

Petitioners were included in a Notice of Suspension No. 2011-004(10), dated August 22, 2011, suspending P2,000,000.00 for payments for financial assistance granted to Pleasant Village Homeowners Association (PVHA) for a flood control project in Pleasant Village Subdivision (PVS), Los Baños, Laguna.
Figueroa requested exclusion from the Notice of Suspension, claiming he was merely an alternate signatory with no custody of funds.
On February 28, 2012, Supervising Auditor Quieta excluded Figueroa from liability in the Notice of Suspension but did not lift the suspension pending submission of documents.
Supporting documents were later submitted, and the Notice of Suspension was lifted on December 19, 2012, subject to re-evaluation.
On February 20, 2013, Notice of Disallowance No. 2013-002(10) was issued disallowing the P2,000,000 payment because PVHA was a private association and PVS had not been turned over to the local government, making the use of public funds improper.

Petitioners filed appeals with the COA Corporate Government Sector, Cluster 6, but both were denied in Decision No. 2014-004 dated April 28, 2014.
COA affirmed the disallowance holding the financial assistance failed the public purpose test as PVHA remained a private association.
Petitioners filed petitions for review before the COA Commission Proper.
In a September 6, 2017 Decision, COA dismissed Figueroa’s petition, holding him personally liable for negligence in signing the vouchers without written objection, and upheld the disallowance.
Genuino’s petition was initially dismissed as time-barred but later reinstated as timely; however, on merits, COA dismissed it affirming disallowance and held Genuino solidarily liable.

Genuino filed a Petition for Certiorari before the Supreme Court which granted the petition on June 15, 2021 (2021 Genuino Decision), setting aside COA decisions on jurisdictional grounds under Section 15 of PD 1869 limiting COA’s audit jurisdiction over PAGCOR.
COA filed a Motion for Reconsideration and Figueroa filed a separate certiorari petition raising similar issues.

Is the COA’s audit jurisdiction over PAGCOR’s funds limited by Section 15 of PD 1869?
Was the issuance of the Notice of Disallowance against the PAGCOR financial assistance proper?
May the petitioners be held personally liable for the disallowed transaction?
Should a stay order be issued in favor of Figueroa?