Case Digest (G.R. No. 258424)
Facts:
In G.R. No. 258424, decided en banc on January 10, 2023 under the 1987 Constitution, the Philippine Health Insurance Corporation (PhilHealth) filed a Petition for Certiorari under Rules 64 and 65, assailing the Commission on Audit (COA) Decision No. 2019-264 (June 25, 2019) and Resolution in Decision No. 2021-262 (October 7, 2021), both upholding COA-Cluster 6 Decision No. 2014-016 (November 14, 2014). COA-Cluster 6 had sustained thirteen Notices of Disallowance (NDs) disallowing PHP 5,010,607.83 in medical mission allowances, representation and transportation allowances, rice, birthday and sustenance gifts, shuttle assistance, public health workers’ benefits, special representation allowances, and longevity pay granted by PhilHealth Regional Office VI for 2011-2012. COA cited lack of legal basis, irregularity or excessiveness, failure to secure a duly reviewed Corporate Operating Budget, and absence of presidential authority under Presidential Decree No. 1597. COA-Cluster heldCase Digest (G.R. No. 258424)
Facts:
- Notices of Disallowance by COA-Corporate Government Sector Cluster 6
- Dates and Benefits/Allowances Disallowed
- Medical Mission Critical Allowance (Jan–Dec 2011) – PHP 499,039.78
- Sustenance and Contractor’s Gifts (Jan–Jun 2012) – PHP 684,149.41
- Medical Mission Critical Allowance (Jan–Jun 2012) – PHP 406,907.67
- Longevity Pay (Jun–Jul 2012) – PHP 126,039.01
- Various allowances (Jul–Aug 2012) – PHP 3,294,471.96
- Grounds for Disallowance
- Lack of legal basis and presidential/DBM approval
- Irregularity or excessiveness
- Failure to submit DBM-reviewed Corporate Operating Budget
- No authority from the Office of the President
- Procedural History
- COA-Cluster Decision No. 2014-016 (Nov 14, 2014)
- Affirmed all NDs; held approving/certifying officers solidarily liable; exempted recipients
- COA Proper Decision No. 2019-264 (Jun 25, 2019)
- Partially granted employees’ petition; relieved recipients
- COA Resolution No. 2021-262 (Oct 7, 2021)
- Modified liability: recipients liable for amounts received; approving/certifying officers remain solidarily liable
- Petition for Certiorari filed by PhilHealth before the Supreme Court
Issues:
- Whether the COA committed grave abuse of discretion in issuing and upholding the NDs
- Whether PhilHealth’s Section 16(n) fiscal autonomy under RA 7875, as amended, exempts it from:
- Salary Standardization Law (RA 6758) and P.D. 1597 approval requirements
- COA rules on allowances and benefits
- Whether recipients, approving officers, or certifying officers must refund the disallowed amounts
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)