Facts:

• Amadeo Matute filed a petition for mandamus on August 8, 1938.
• He entered into a contract with the Commonwealth of the Philippines on December 24, 1936, to supply fresh meat.
• The contract was approved by the Secretary of Finance and specified prices for hindquarters (P0.37 per kilo) and brisket, boneless (P0.38 per kilo).
• Due to increased municipal slaughterhouse fees, Matute requested a price adjustment of 1.5 centavos per kilo, which was granted by Acting Purchasing Agent C.E. Unson with Undersecretary Guillermo Gomez's approval on March 2, 1937.
• Matute supplied hindquarters fresh meat to the Bureau of Prisons from March 1 to 15, 1937.
• On May 31, 1937, the Director of Prisons issued a treasury warrant for P330.73 for the supplied meat, which was sent to the Auditor-General for countersigning.
• The Auditor-General refused to sign, citing lack of public bidding and necessary approvals from the Secretary of Justice and the President.

Issue:

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Ruling:

• The Supreme Court ruled against Matute, denying the petition for mandamus.
• The Court held that the Auditor-General has discretion to determine the legality of expenditures.
• The amendment to the contract was deemed invalid due to...(Unlock)

Ratio:

• The Court's decision was based on Section 2, Article X of the 1935 Constitution, which grants the Auditor-General authority to audit and settle government expenditure accounts.
• The Auditor-General's role is not merely ministerial; he has discretion to evaluate expenditures for irregularities.
• The price increase constituted a novation of t...continue reading