Case Digest (G.R. No. 185812)
Facts:
Maritime Industry Authority v. Commission on Audit, G.R. No. 185812, January 13, 2015, the Supreme Court En Banc, Leonen, J., writing for the Court.
Petitioner Maritime Industry Authority (MARINA) is an attached agency of the Department of Transportation and Communication created under Presidential Decree No. 474. The case arose after MARINA restored and paid various allowances and incentives to its officers and employees beginning January 2001, relying on an internal memorandum dated February 10, 2000 that MARINA says was approved by then President Estrada on October 16, 2000.
The Resident Auditor of MARINA issued several notices of disallowance (totaling ₱5,565,445.02) for allowances and benefits paid from January to May 2001 (including rice subsidy, medical allowance, performance incentive allowances, birthday/anniversary bonuses, representation/commutable/per diems for board members, and various other allowances). The Legal and Adjudication Office of the Commission on Audit (COA) upheld those notices; the COA Commission Proper affirmed in a decision dated March 3, 2005 (denying MARINA’s petition for review except as to a per diem/commutable allowance of board members at ₱500 per month); MARINA’s motion for reconsideration was denied by COA Resolution No. 2008-117 dated December 9, 2008.
MARINA sought review in the Supreme Court by petition for certiorari (Rule 64/Rule 65-type extraordinary relief challenging COA’s action), alleging among other things that COA committed grave abuse of discretion and that the payments were authorized by the President’s alleged approval and thus lawful. COA filed a comment; MARINA filed a reply. The sole legal question framed for the Court was whether the allowances and incentives had a legal basis.
The Supreme Court, speaking through Justice Leonen, denied the petition. The Court found COA did not commit grave abuse of discretion, held that the contested allowances were integrated into standardized salaries under Republic Act No. 6758 (RA 6758) Section 12 (and not lawfully payable in addition to salary), that the purported presidential approval was neither proven nor sufficient as a legislative authorization, and that the disbursements therefore amounted to prohibited double compensation in violation of Article IX(B), Section 8 ...(Subscriber-Only)
Issues:
- Did the Commission on Audit commit grave abuse of discretion amounting to lack or excess of jurisdiction in disallowing the contested allowances?
- Were the allowances and incentives granted to MARINA officers and employees legally payable in addition to their standardized salaries under RA 6758 Section 12 (and was the alleged presidential approval a sufficient legal basis)?
- Are the approving officers and payees requi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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