Case Digest (G.R. No. 235832)
Facts:
Philippine Health Insurance Corporation v. Commission on Audit, G.R. No. 235832, November 03, 2020, the Supreme Court En Banc, Inting, J., writing for the Court. Petitioner is Philippine Health Insurance Corporation (PHIC); respondents are the Commission on Audit (COA), through Chairperson Michael G. Aguinaldo, and Director IV Angelina B. Villanueva.The controversy arose after the PHIC Resident Auditor issued several Notices of Disallowance (NDs) disallowing various benefits and allowances granted by the PHIC Board of Directors to PHIC personnel for calendar years 2007–2008 and related payments, totaling P204,072,574.37. Except for an ND concerning payment of liability insurance premiums (ND HO2009-001), the Resident Auditor grounded the disallowances on lack of prior approval from the Office of the President under Memorandum Order No. 20 (2001) and Administrative Order No. 103 (2004); ND HO2009-001 was held to violate Section 73, R.A. No. 9184 and a GPPB resolution.
PHIC filed consolidated memoranda of appeal with the COA Corporate Government Sector A (COA-CGS), but on July 12, 2012 the COA-CGS denied PHIC’s appeals and upheld the NDs. PHIC then sought review with the COA-Commission Proper (COA Proper). On December 27, 2016 the COA Proper issued Decision No. 2016-436: it denied the petition with respect to ND No. HO2009-005-725(08) (Efficiency Gift) on the merits but dismissed PHIC’s petition as to the other NDs for late filing, holding that PHIC failed to perfect its appeal within the six-month reglementary period under the COA Rules. The COA Proper denied PHIC’s motion for reconsideration by Resolution No. 2017-050 dated September 7, 2017.
PHIC then filed a Petition for Certiorari under Rule 64 in relation to Rule 65 of the Rules of Court before the Supreme Court, praying also for a Temporary Restraining Order (TRO) and writ. The Court issued a TRO on January 30, 2018 enjoining respondents from executing the COA Proper decision and resolution. PHIC argued that (1) COA committed grave abuse in dismissing the petition on procedural grounds because PHIC had timely filed a motion for extension of time, and (2) PHIC’s charter granted it fiscal autonomy to fix compensation and authorize the disputed benefits (including reliance on collective bargaining, past OP confirmations, and classification as...(Pro-only)
Issues:
- Did the COA-Commission Proper commit grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing PHIC’s petition for review as to certain NDs for late filing?
- Were the disallowed benefits validly granted by PHIC by virtue of its claimed fiscal autonomy to fix compensation and benefits?
- Are the approving/certifying PHIC officers and the recipients of the Efficiency Gift liable to return the disallowe...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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