Case Digest (G.R. No. 103982) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Antonio A. Mecano, a Director II of the National Bureau of Investigation, was hospitalized for cholecystitis from March 26 to April 7, 1990, and incurred medical and hospitalization expenses amounting to ₱40,831.00. On May 11, 1990, he sought reimbursement under Section 699 of the *Revised Administrative Code* (RAC), as amended, by forwarding his claim through a memorandum to Director Alfredo S. Lim. Director Lim submitted the claim with favorable recommendations from the NBI’s Legal and Examination Division and the Department of Justice’s Committee on Physical Examination. Undersecretary Silvestre H. Bello III returned the claim, citing a 5th Indorsement of the Commission on Audit (COA) which asserted that Section 699 had been repealed by the Administrative Code of 1987. Mecano refiled, supported by *Opinion No. 73, S. 1991* of Secretary Franklin M. Drilon stating Section 699 remained effective. Despite Secretary Drilon’s favorable 6th Indorsement, COA Chairman Eufemio C. Domin Case Digest (G.R. No. 103982) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Jurisdiction
- Antonio A. Mecano, petitioner, is a Director II of the National Bureau of Investigation (NBI).
- The Commission on Audit (COA) is the respondent agency that denied his claim.
- Chronology of Claim and Proceedings
- Mecano was hospitalized for cholecystitis from March 26 to April 7, 1990, incurring P40,831.00 in medical and hospital expenses.
- May 11, 1990: Mecano requested reimbursement under Section 699 of the Revised Administrative Code (RAC) by memorandum to NBI Director Alfredo S. Lim.
- June 22, 1990: Director Lim’s 1st Indorsement, with Gerarda Galang’s favorable comment, forwarded the claim to the Secretary of Justice; the DOJ Committee on Physical Examination recommended payment as service-connected.
- September 19, 1990: COA’s 5th Indorsement opined that Section 699 was repealed by the Administrative Code of 1987; Undersecretary Bello returned the claim (4th Indorsement, Nov. 21, 1990).
- April 26, 1991: Justice Secretary Drilon issued Opinion No. 73, S. 1991, holding that the 1987 Code did not repeal Section 699.
- May 10 & July 2, 1991: Director Lim’s 5th and 6th Indorsements, accompanied by Opinion No. 73, were sent to the COA Chairman.
- January 16, 1992: COA’s 7th Indorsement denied the claim for lack of statutory basis, suggesting recourse to the Employees’ Compensation Commission.
- February 7, 1992: Undersecretary Montenegro’s 9th Indorsement advised Mecano to elevate the matter to the Supreme Court.
- Relief Sought
- A petition for certiorari before the Supreme Court to nullify COA’s denial.
- Declaration that Section 699 of the RAC remains in force and entitles Mecano to P40,831.00 reimbursement.
Issues:
- Primary Issue
- Whether the Administrative Code of 1987 (Executive Order No. 292) repealed or abrogated Section 699 of the Revised Administrative Code of 1917.
- Ancillary Issue
- Whether filing a claim with the Employees’ Compensation Commission bars concurrent recovery under Section 699 of the RAC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)