G.R. No. 227926 - Province of Camarines Sur vs. Commission on Audit

Procedural Background
Petition for Certiorari under Rule 64 and Rule 65 filed by the Province of Camarines Sur, represented by Governor Miguel Luis R. Villafuerte, to nullify:

These COA issuances affirmed with finality COA-RO V Decision No. 2013-L-016, which sustained Notice of Disallowance No. 2011-200-010(08) disallowing P 5,820,843.30.

Facts of the Transaction and Audit
Since 1999, the Province hired temporary teaching personnel for extension classes and non-teaching personnel for their operation, charging salaries and allowances to the Special Education Fund (SEF) under Section 272, R.A. No. 7160 (LGC).
On February 18, 2009, COA-ATL issued Audit Observation Memorandum No. 2009-19, finding the July–October 2008 payments of P 5,820,843.30 contravened Section 272, R.A. 7160 and DECS-DBM-DILG Joint Circular No. 01 series 1998 (and its JC 01-A, JC 01-B).
The Province’s officers-in-charge of accounting, treasury and budget contended in a June 23, 2010 comment that SEF utilization was proper and within the fund’s object.
On November 15, 2011, COA-ATL and Supervising Auditor issued Notice of Disallowance No. 2011-200-010(08) disallowing the allowances on grounds that:

Extension classes lacked prior DECS Secretary approval and Regional Director recommendation.
No MOA or Accomplishment Report, improper accounting classification, missing approvals by Provincial Governor/Accountant/Budget Officer, and absence of head teachers’ certifications.

The Notice held five provincial officers personally liable.
The Province appealed to COA-RO V (Decision No. 2013-L-016), and then to COA proper (Decision No. 2014-454), both denying relief. A motion for reconsideration was denied by COA Resolution No. 2016-268.

Abuse of Discretion / Jurisdiction
Whether COA acted with grave abuse of discretion amounting to lack or excess of jurisdiction in disallowing payments despite compliance with Section 272, LGC.
Whether COA abused discretion in rejecting the joint certification by the Acting HRMO and Schools Division Superintendent as sufficient proof of service render.

Validity of Joint Circular No. 01-A
Whether the approval, recommendation and certification requirements imposed by the DECS-DBM-DILG JC No. 01-A exceed the agencies’ rule-making power and violate LGU local autonomy.