Case Digest (G.R. No. 242342)
Facts:
In National Power Corporation Board of Directors v. Commission on Audit, petitioners Margarito B. Teves, Rolando G. Andaya Jr., Peter B. Favila, Arthur C. Yap, Eleazar P. Quinto, Ronaldo V. Puno, Augusto B. Santos, and Froilan A. Tampinco, acting as the Board of Directors of the National Power Corporation (NPC), adopted Board Resolution No. 2009-52 on September 10, 2009, to grant the Employee Health and Wellness Program and Related Financial Assistance (EHWPRFA) of ₱5,000.00 per month, paid quarterly, to qualified NPC officials and employees. On September 26, 2011, the Commission on Audit (COA) issued Notice of Disallowance No. NPC-11-004-10 disallowing ₱29,715,000.00 for the first quarter of 2010 on the ground that the EHWPRFA was a “new benefit” lacking the prior approval of the President as required under Memorandum Order No. 20 (June 25, 2001). The COA Corporate Government Sector-Cluster 3 affirmed this disallowance in its December 27, 2013 Decision. Upon appeal, the COA enCase Digest (G.R. No. 242342)
Facts:
- Authorization of EHWPRFA
- On September 10, 2009, the NPC Board of Directors adopted Board Resolution No. 2009-52 to grant an Employee Health and Wellness Program and Related Financial Assistance (EHWPRFA), consisting of a P5,000 monthly cash benefit, released quarterly, to qualified officials and employees.
- The benefit was paid for the first quarter of 2010, totaling P29,715,000.00.
- Post-audit disallowance and COA rulings
- COA issued Notice of Disallowance No. NPC-11-004-10 (Sept. 26, 2011), disallowing the Q1-2010 EHWPRFA for lacking prior approval from the President/DBM under M.O. No. 20 (2001).
- COA Corporate Government Sector-Cluster 3 (Dec. 27, 2013) and COA Proper (Feb. 16, 2017) affirmed the disallowance.
- COA Resolution (Mar. 15, 2018) partially granted reconsideration by absolving passive recipients from refund (good-faith defense) but maintained liability of approving/authorizing officers.
- Petition before the Supreme Court
- NPC officers filed a petition for certiorari under Rule 64 challenging COA’s rulings.
- Issues raised: whether EHWPRFA was a “new benefit” and whether it needed presidential approval.
Issues:
- Whether the Commission on Audit gravely abused its discretion in ruling that EHWPRFA was a new benefit.
- Whether the Commission on Audit gravely abused its discretion in ruling that the grant of EHWPRFA required prior approval of the President.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)