Facts:

The case involves the National Amnesty Commission (NAC) as the petitioner and the Commission on Audit (COA), along with its officials Juanito G. Espino and Ernesto C. Eulalia, as respondents. The events leading to this case began on March 25, 1994, when the NAC was established by then-President Fidel V. Ramos through Proclamation No. 347. The NAC is responsible for processing amnesty applications and is composed of a Chairperson, three regular members appointed by the President, and three ex officio members who are the Secretaries of Justice, National Defense, and Interior and Local Government.

After attending initial meetings, the three ex officio members delegated their responsibilities to representatives who began receiving honoraria starting December 12, 1994. However, on October 15, 1997, Eulalia, the NAC's resident auditor, disallowed the payment of these honoraria, amounting to P255,750, citing COA Memorandum No. 97-038. The National Government Audit Office (NGA...

Facts:

1. Creation and Composition of the National Amnesty Commission (NAC):
   The NAC was created on March 25, 1994, by Proclamation No. 347 issued by then President Fidel V. Ramos. It is composed of seven members: a Chairperson, three regular members appointed by the President, and the Secretaries of Justice, National Defense, and Interior and Local Government as ex officio members.

2. Payment of Honoraria to Representatives:
   After initially attending NAC meetings, the ex officio members designated their representatives to attend on their behalf. These representatives were paid honoraria starting December 12, 1994.

3. Disallowance of Honoraria by COA:
   On October 15, 1997, NAC resident auditor Ernesto C. Eulalia disallowed the payment of honoraria to the representatives, amounting to P255,750 for the period December 12, 1994, to June 27, 1997, citing COA Memorandum No. 97-038. The National Government Audit Office (NGAO) upheld this disallowance on September 1, 1998.

4. Administrative Order No. 2:
   On April 28, 1999, the NAC passed Administrative Order No. 2, which allowed ex officio members to designate representatives and entitled them to per diems, allowances, bonuses, and other benefits as authorized by law. This order was approved by then President Joseph Estrada on October 19, 1999.

5. Petition to COA:
   The NAC challenged the disallowance before the COA, invoking Administrative Order No. 2. However, the COA upheld the disallowance in its decisions dated July 26, 2001, and January 30, 2003.

6. Petition to the Supreme Court:
   The NAC filed a petition with the Supreme Court, arguing that the COA committed grave abuse of discretion in disallowing the honoraria and in declaring Section 1, Rule II of Administrative Order No. 2 null and void.

Issue:

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Ruling:

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Ratio:

1. Constitutional Mandate of COA:
   The COA has the constitutional mandate to ensure that government funds are used validly and efficiently. This includes the power to disallow irregular, unnecessary, or extravagant expenditures.

2. Prohibition on Multiple Positions and Double Compensation:
   The Constitution prohibits Cabinet members, their deputies, and assistants from holding multiple offices and receiving additional compensation, unless expressly authorized by the Constitution itself. This prohibition extends to their representatives.

3. Internal Regulations Do Not Require Publication:
   COA Memorandum No. 97-038 is an internal regulation that does not require publication to be effective. It is a directive to enforce existing constitutional and statutory prohibitions.

4. Designation vs. Appointment:
   Designation does not confer the right to receive additional compensation. Only a duly issued and approved appointment entitles an official to the salary and benefits of a position.

5. No Good Faith Defense:
   The representatives cannot claim good faith in receiving allowances, as the constitutional prohibitions were already established and final at the time they received the payments.

Conclusion:

The Supreme Court upheld the COA's disallowance of the honoraria paid to the representatives of the NAC ex officio members, ruling that such payments were prohibited by the Constitution. The Court also declared Section 1, Rule II of Administrative Order No. 2 null and void to the extent that it authorized the payment of allowances to these representatives. The petition was dismissed for lack of merit.