Case Digest (G.R. No. 244128) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mario M. Madera, et al. v. Commission on Audit, G.R. No. 244128, decided September 8, 2020, the Supreme Court sat En Banc to review a certiorari petition by the Municipal Mayor (Mario Madera), Municipal Accountant (Beverly Mananguite), Municipal Treasurer (Carissa Galing), and Municipal Budget Officer (Josefina Pelo) of Mondragon, Northern Samar, against the Commission on Audit (COA) and its Regional Office No. VIII. In December 2013, the Sangguniang Bayan enacted Ordinance No. 08 and Resolutions Nos. 41, 42, 43, and 48 (all series of 2013), authorizing four year-end allowances—Economic Crisis Assistance (ECA), Monetary Augmentation of Municipal Agency (MAMA), Agricultural Crisis Assistance (ACA), and Mitigation Allowance to Municipal Employees (MAME)—totaling ₱7,706,253.10, allegedly to assist low-income workers and farmers after Typhoon “Yolanda.”During the post‐audit, two COA auditors issued eleven Notices of Disallowance on February 20, 2014, declaring the subject all
Case Digest (G.R. No. 244128) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- In December 2013 the Municipality of Mondragon, Northern Samar enacted Sangguniang Bayan Ordinance No. 08 and Resolutions Nos. 41, 42, 43, and 44 (series of 2013), granting four year‐end allowances—Economic Crisis Assistance (ECA), Monetary Augmentation of Municipal Agency (MAMA), Agricultural Crisis Assistance (ACA), and Mitigation Allowance to Municipal Employees (MAME)—totaling ₱7,706,253.10 to officials and employees (regular, casual, job‐order, barangay workers, teachers, national staff).
- Petitioners Mario M. Madera (Mayor), Beverly C. Mananguite (Municipal Accountant), Carissa D. Galing (Treasurer), and Josefina O. Pelo (Budget Officer) certified and approved these disbursements.
- Audit and Notices of Disallowance
- On post‐audit, the COA issued 11 Notices of Disallowance dated February 20, 2014, citing violation of Sec. 12 of RA 6758 (Salary Standardization Law), COA Circular No. 2013-003, and CSC Resolution No. 02-0790.
- Those charged: approving officers (Mayor, Accountant, Treasurer, Budget Officer) and all payees who received the allowances.
- COA Regional and COA Proper Decisions
- COA Regional Director (July 14, 2015) affirmed disallowance:
- SSL Sec. 12 integrates unlisted allowances in salary.
- LGC (RA 7160) did not repeal SSL.
- Ordinance insufficient as standalone legal basis.
- COA Proper (Decision Dec. 27, 2017) affirmed with modification:
- Approving officers and those who participated in approval to refund full amounts.
- Passive recipients in good faith excused from refund.
- Motion for Reconsideration and Supreme Court Petition
- Motion for Reconsideration denied Aug. 16, 2018.
- Petition for certiorari filed Jan. 11, 2019 under Rules 64/65, assailing COA’s decision and joint‐and‐several refund liability.
Issues:
- Timeliness
- Whether the Petition filed Jan. 11, 2019 was timely under Rule 64’s 30-day period.
- Merits
- Whether COA gravely abused discretion in disallowing the allowances.
- Whether COA correctly imposed joint and solidarity liability on petitioners for refund.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)