Facts:

• The case involves the Philippine Health Insurance Corporation (PHIC) as the petitioner and the Commission on Audit (COA) as respondents.
• Several Notices of Disallowance (NDs) were issued by PHIC's Resident Auditor, Elena L. Agustin, against benefits granted by the PHIC Board of Directors to its personnel.
• The NDs, issued on December 18, 2008, and September 14 and 30, 2009, totaled approximately P204 million and included various allowances and gifts.
• The auditor disallowed these benefits due to lack of necessary approval from the Office of the President, as required by Memorandum Order No. 20 and Administrative Order No. 103.
• PHIC appealed the NDs to COA-Corporate Government Sector A (COA-CGS), which affirmed the disallowances on July 12, 2012.
• PHIC filed a petition for review with the COA Proper, which dismissed the petition on December 27, 2016, for late filing and lack of merit regarding the efficiency gift.
• PHIC's motion for reconsideration was denied on September 7, 2017, leading to a petition for certiorari before the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the COA Proper did not commit grave abuse of discretion in dismissing PHIC's petition for review due to late filing.
• The Court found that PHIC lacked a legal basis for granting the disallowed benefits, as they were not approved by the Office of the President.
• The Court concluded that PHIC officials who au...(Unlock)

Ratio:

• The Supreme Court emphasized that the COA Proper acted within its jurisdiction and did not abuse its discretion in dismissing PHIC's appeal due to late filing.
• The Court reiterated that timely filing of an appeal is jurisdictional, and PHIC's failure to file within the reglementary period rendered the COA-CGS's decision final and executory.
• PHIC's claim of fiscal autonomy under R.A. No. 7875 does not exempt it from compliance with laws governing the grant of benefits.
• The benefits were not expl...continue reading