G.R. No. 237874 - Wycoco vs. Aquino

Petitioners: Clarito A. Poblete (former Municipal Mayor of Silang, Cavite), Ma. Dolores Jeaneth Bawalan (Municipal Budget Officer), Nephtali V. Salazar (Municipal Accountant).
Respondent: Commission on Audit (COA).

On June 2, 2011, COA’s Audit Team Leader and Supervising Auditor issued 12 Notices of Disallowance (ND) totaling ₱2,891,558.31 against the Municipality of Silang for various locally undertaken projects from 2004, 2006, and 2007.
These projects were paid using the Municipality’s 2010 appropriations, in violation of Section 350 of the Local Government Code (LGC), which mandates that all expenditures and obligations must be accounted for in the fiscal year they were incurred.
The petitioners were named liable for these disallowances.

COA Regional Office affirmed the disallowances on August 1, 2013, holding contracts void for lack of prior appropriation and certificate of availability of funds as required by law.
Petitioners filed a Petition for Review with the COA Proper through the Commission Secretariat.
The COA Proper dismissed the Petition for Review on February 23, 2015, for being filed out of time due to late payment of the required filing fees.
A subsequent Motion for Reconsideration was denied on November 27, 2015.

Petitioners argued the six-month period under the 2009 Revised Rules of Procedure of the COA (RRPC) is suspended upon filing the petition regardless of the payment date of filing fees.
They claimed they were made to pay filing fees twice and that payment is not mandatory and jurisdictional.
They cited a letter from the Commission Secretary directing payment of fees on August 29, 2013, to cure any defect.
They applied the principle of quantum meruit to justify payment for completed projects.
Petitioner Poblete invoked the Arias Doctrine to absolve him of liability.

COA held that filing fees must be paid upon filing, supported by COA Resolution No. 2008-005 and 2009 RRPC.
They emphasized that Section 350 LGC was violated and that the Arias Doctrine did not apply because the irregularity was manifest.
The principle of quantum meruit was deemed inapplicable.

Petitioners filed a Petition for Certiorari under Rule 65 to contest COA’s dismissal and resolution.
They filed additional pleadings to clarify and support their arguments.

Whether the Commission on Audit gravely abused its discretion in dismissing the petitioners’ Petition for Review on the ground of failure to file it within the prescribed reglementary period.

Whether the principle of quantum meruit applies in the payment for projects that were funded from appropriations not allocated in the correct fiscal year.

Whether the Arias Doctrine shields the petitioner Mayor Poblete from liability under these circumstances.

Whether the use of the 2010 budget to pay obligations from previous years violated Section 350 of the LGC and related rules governing government contracts.