G.R. No. 211933 - Saldariega vs. Panganiban

The case involves a petition for certiorari under Rule 64, in relation to Rule 65, challenging COA decisions.
Petitioners are the Philippine Charity Sweepstakes Office (PCSO), represented along with petitioning officers.
The underlying issue arises from the disallowance of several monetary benefits granted by the Laguna Provincial District Office (LPDO) of PCSO in November 2010.
The disallowed benefits include allowances such as the Christmas Bonus, Weekly Draw Allowance, Staple Food Allowance, Hazard Pay, Cost of Living Allowance (COLA), and Medicine Allowance.

ND No. PCSO 2010-16-101(2010): Christmas Bonus for calendar year 2010 equivalent to three months basic salary amounting to P1,459,050.60, disallowed due to the lack of legal basis, being solely based on a union collective negotiation agreement and an internal PCSO resolution.
ND No. PCSO 2010-17-101(2010): Weekly Draw Allowance for the period of 8 to 28 November 2010 amounting to P40,200.00, disallowed for the same reason.
ND No. PCSO 2010-18-101(2010): Combined allowances (Staple Food, Hazard, COLA, and Medicine) amounting to P101,816.89, disallowed as COLA was already integrated into the basic salary per the Salary Standardization Law and the benefits lacked an independent legal basis.

The total disallowed amount was computed at P1,601,066.89.
Petitioners contended that the disallowed benefits had been retrospectively approved by the Office of the President through a post facto letter dated 19 May 2011.

Petitioners failed to file the initial appeal on time, leading to a Notice of Finality of Decision.
Claiming inadvertence, PCSO sought reconsideration based on the alleged post facto approval.
COA Assistant Commissioner Elizabeth Zosa allowed the late appeal by ordering the COA Regional Director to consider the petition.
The COA Regional Director, however, upheld the validity of the original Notices of Disallowance.
Petitioners escalated the matter by filing a petition for review before the COA Proper.
Initially, the COA Proper dismissed the petition for being untimely but later, upon motion for reconsideration, resolved the case on the merits by affirming the disallowance.

Petitioners challenged the dismissal of their petition for review on grounds that the late appeal was accepted by the Assistant Commissioner.
They argued that the PCSO Board had the authority under Republic Act (RA) No. 1169 to fix the salaries and other monetary benefits of its officials and employees, including the disallowed monetary benefits.
They asserted that the benefits enjoyed post facto approval by the Office of the President through the letter of Executive Secretary Paquito N. Ochoa, Jr.
Petitioners further contended that disallowing such benefits would violate the principle of non-diminution of benefits and that they acted in good faith while merely executing PCSO Board orders.

Whether the COA Proper erred in dismissing the petition for review for being filed out-of-time, given that the late appeal was accepted by the Assistant Commissioner.

Whether the PCSO Board possessed plenary authority under RA No. 1169 to fix the salaries and monetary benefits of PCSO officials and employees.
Whether the alleged post facto approval by the Office of the President validly ratified the disbursed benefits.

Whether the disallowance of the benefits, including the Christmas Bonus, Weekly Draw Allowance, Staple Food Allowance, COLA, and Medicine Allowance, was proper in light of the pertinent civil service and compensation laws.
Whether such disallowance violates the doctrine of non-diminution of benefits.

Whether the approving/certifying officers who participated in the release of the funds are liable for the disallowed amounts based on their actions and the application of the Madera Rules.
Whether any equitable exceptions (e.g., undue prejudice or humanitarian considerations) could be invoked to excuse the return of the disallowed benefits.