Case Digest (G.R. No. 238676)
Facts:
- Parties Involved: Petitioners Elaine E. Navarro and Raul L. Orozco vs. the Commission on Audit (COA).
- Origin: Representatives Francisco T. Matugas and Guillermo A. Romarate, Jr. sought financial assistance from then-President Gloria Macapagal-Arroyo for textbooks and instructional materials for schools in Surigao del Norte.
- Approval and Procurement: DepEd Secretary Jesli A. Lapus approved the requests, leading to Sub-Allotment Release Orders in 2008. Consequently, the DepEd Caraga Regional Office procured materials worth P18,298,789.50.
- Audit Observation: On February 17, 2009, COA issued Audit Observation Memorandum (AOM) No. DepEdRO13-2009-003, citing irregularities and violation of DepEd Orders that imposed a moratorium on such purchases.
- Suspension and Disallowance: Despite explanations from DepEd officials, COA issued Notice of Suspension No. 09-003-101-(08) and later Notice of Disallowance No. 09-005-101-(08), mandating Navarro and Orozco to refund the amount.
- Appeals: The petitioners appealed to the COA Regional Office No. XIII, which partially granted their appeal by reducing the disallowed amount. However, upon automatic review, the COA reinstated the full disallowance.
- Supreme Court: The petitioners sought relief from the Supreme Court, arguing that their right to a speedy disposition of cases was violated.
Issue:
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Ruling:
- Supreme Court Decision: The Supreme Court ruled in favor of the petitioners, granting the petition on the grounds that their constitut...(Unlock)
Ratio:
- Constitutional Guarantee: Section 16, Article III of the 1987 Constitution guarantees the right to a speedy disposition of cases before all judicial, quasi-judicial, and administrative bodies.
- Balancing Test: The right is not absolute but flexible, depending on the facts and circumstances of each case. The Court applied the balancing test, considering the length of delay, reasons for the delay, the petitioners' assertion of their right, and the prejudice caused by the delay.
- Unreasonable Delay: The delay of more than seven years from the issuance of AOM No. DepEdRO13-2009-003 to the COA's decision was deemed unreasonable.
- Burden of Proof: The COA failed to justify the delay or prove that it...continue reading
Case Digest (G.R. No. 238676)
Facts:
In the case of "Navarro v. Commission on Audit Central Office," petitioners Elaine E. Navarro and Raul L. Orozco contested the Commission on Audit's (COA) decision to disallow the purchase of reference materials by the Department of Education (DepEd) due to alleged irregularities. The case originated when Representatives Francisco T. Matugas and Guillermo A. Romarate, Jr. sought financial assistance from then-President Gloria Macapagal-Arroyo for acquiring textbooks and instructional materials for schools in Surigao del Norte. DepEd Secretary Jesli A. Lapus approved these requests, leading to the issuance of Sub-Allotment Release Orders in 2008. Consequently, the DepEd Caraga Regional Office procured materials worth P18,298,789.50. On February 17, 2009, COA issued Audit Observation Memorandum (AOM) No. DepEdRO13-2009-003, highlighting that the procurement was irregular and violated DepEd Orders that imposed a moratorium on such purchases. Despite explanations from DepEd officials, COA issued Notice of Suspension No. 09-003-101-(08) and later Notice of Disallowance (ND) No. 09-005-101-(08), mandating Navarro and Orozco to refund the amount. The petitioners appealed to the COA Regional Office No. XIII, which partially granted their appeal by reducing the disallowed amount. However, upon automatic re...