G.R. No. 253199 - Raul F. Macalino vs. Commission on Audit

Raul F. Macalino ran for vice mayor of San Fernando City, Pampanga, in May 2013 and lost.
On July 1, 2013, the Municipal Government of Mexico, Pampanga, through Mayor Roy D. Manalastas, entered into a Contract of Service with Macalino to serve as Legal Officer II from June 1, 2013 to July 30, 2014 at a monthly salary of PHP 26,125.00.

On March 28, 2014, the COA issued Notice of Disallowance No. 14-001-100-(13) disallowing PHP 149,015.00 (wages and PERA for July–December 2013) paid to Macalino for violating Article IX-B, Section 6 of the Constitution and Section 94 of the Local Government Code; eight municipal officers—including Macalino—were held liable.
Macalino appealed to COA Regional Office No. III, which on November 12, 2014 affirmed the disallowance. He then elevated the case to COA Proper (treated as a petition for review), which on August 9, 2019 (Decision No. 2019-305) and January 21, 2020 (Resolution) denied his petition. He filed a Petition for Certiorari before the Supreme Court.

Whether the one-year prohibition under Article IX-B, Section 6, Constitution, and Section 94(b), RA 7160, applies to Macalino’s Contract of Service appointment.
Whether Macalino’s engagement as “consultant” falls outside civil service and COA rules on appointment and private legal counsel employment.
Whether Macalino and the approving/certifying officers are civilly liable for returning the PHP 149,015.00 and if the quantum meruit principle under Torreta v. COA applies.