G.R. No. 100284 - Mamaril vs. Domingo

Narciso E. Mamaril, the petitioner, formerly served as an Evaluator/Computer at the Land Transportation Office (LTO) in San Pablo City.
His work involved the evaluation and computation of fees related to the registration of motor vehicles, a process that required his input twice—first for computation and later for review.
Petitioner was selected for the Early Retirement Program under Republic Act No. 6683.

In the performance of his duties, petitioner committed repeated errors in his evaluation and computation.

From January 1983 to February 1989, he made 479 erroneous evaluations and computations with discrepancies ranging from P1.00 to P1,675.00.
These errors contributed to the undercollection of various fees (registration, license, and other miscellaneous fees and penalties).

The COA, through Decision No. 1614, identified petitioner’s errors as negligent performance of his duties.

The COA ordered that an amount of P44,515.90 be withheld from petitioner’s terminal leave pay, explicitly excluding his retirement gratuity.
The decision was anchored on the fact that petitioner repeatedly received 17 Certificates of Settlement and Balances and 14 Notices of Suspension, which he failed to address or appeal.

Petitioner argued that his role was purely clerical and mechanical, and he did not have possession of government money or property.

He asserted that he should not be held liable on the disallowances since he was not an “accountable officer” under Section 101 of P.D. No. 1445 (1978).
Petitioner also contended that the COA’s decision itself advised the concerned agency to pursue collection from delinquent parties liable for the under collections.
He alleged that the disallowances were never properly explained nor was he given an effective opportunity to be heard to address the issues raised.

The LTO’s internal process required that the fees to be collected pass through the Evaluator/Computer twice—first for evaluation and computation, then for review.
After the official receipt was prepared, it had to be returned for a review by the same Evaluator/Computer, who was responsible for checking and correcting any errors before final approval by the agency head.

Whether the petitioner could be held liable for audit disallowances given his clerical role, especially considering he did not handle government funds directly.

The petitioner disputed his classification as an “accountable officer” under Section 101 of P.D. No. 1445 (1978).
He contended that mere clerical errors, absent malicious intent or gross negligence, should not render him civilly liable for the financial discrepancies.

Whether the COA exercised its constitutional authority properly in ordering the withholding of P44,515.90 from petitioner’s terminal leave pay (excluding retirement gratuity).

The issue also revolved around the power of the COA to define the scope of its audit, including internal control and accounting functions within government agencies.
The petitioner questioned if the rights to due process were observed, especially regarding the lack of detailed explanation of disallowances and the alleged denial of the opportunity to be heard.