G.R. No. 263155 - Tiblani et al. vs. Commission on Audit

On January 10, 2001, Civil Service Commission (CSC) issued Resolution No. 010112 establishing the Program on Awards and Incentives for Service Excellence (PRAISE) for government agencies.
Subsequent CSC Memorandum Circular No. 1, s. 2001 adopted revised policies on PRAISE requiring agencies to create their own awards and incentive systems subject to CSC guidelines.
Pursuant to this, the National Economic Development Authority Central Office (NEDA-CO) issued Office Circular No. 03-2005 on April 26, 2005, creating the NEDA Awards and Incentives System (NAIS) which included the Cost Economy Measure Award (CEMA).
CEMA was described as an award granted to employees or teams whose ideas, inventions, or performance resulted in savings or benefits to the agency. It had no cap on number of recipients.
Qualifications, nomination procedures, and period of reference for CEMA were detailed in NAIS, including entitlement on pro-rated basis for lesser service times, and non-entitlement if AWOL or no longer in service at grant time.
CSC-NCR Director certified that the NAIS complied with CSC MC No. 1, s. 2001 on August 10, 2005.

NEDA-CO granted CEMA to officials and employees, including petitioners, for years 2010, 2011, and 2012.
On April 12, 2013, a supervising auditor issued an Audit Observation Memorandum (AOM) requiring refund of CEMA granted from 2010 to 2012.
On May 7, 2013, COA issued Notice of Disallowance (ND) No. 2013-01-101 disallowing the grant of CEMA on grounds:

CEMA not authorized under Senate and House Joint Resolution No. 4, s. 2009.
Payment lacked specific appropriation and presidential authorization as required by law and General Appropriations Acts (GAAs) for 2010-2012.
CSC lacked authority to allocate executive branch savings to pay CEMA.
Payment lacked clear criteria or standards to assess superior or extraordinary accomplishments.

Both petitioners (payees) and NEDA-CO approving officers filed appeals against the ND in 2013.
COA’s National Government Sector Cluster 2 affirmed the ND but exempted employees who merely received the CEMA from liability to refund.
The case was elevated for automatic review to COA Commission Proper (COA-CP) which on December 13, 2017, affirmed the ND and ruled:

CEMA was unauthorized and lacked legal basis.
GAAs prohibited expenditures for unauthorized allowances.
Presidential decree requires prior presidential approval before additional allowances could be paid.
Lack of sufficient objective standards for grant of CEMA.
Exempted mere passive recipients from refund liability but held approving officers liable.

NEDA’s approving and certifying officers filed motions for reconsideration, but petitioners-payees did not.
On January 24, 2022, COA-CP issued Resolution No. 2022-094 partly granting officers’ motions but reinstating liability of payees to return amounts.
Petitioners filed this Petition for Certiorari challenging the reinstatement of their liability.

Court addressed the authority of affiants to file the petition on behalf of numerous employees listed in Annex A.
Petitioners submitted Special Powers of Attorney authorizing a petitioner named Maria Genelin L. Licos to represent others.
Though incomplete in formality, Court relaxed strict requirements and accepted the representation for purposes of resolving the case on merits.

COA contends disallowance proper due to lack of legal basis and procedural requirements.
Petitioners argue presidential approval not necessary, CEMA was not an additional allowance, and they received awards in good faith.
Petitioners invoke social justice and the passage of time, COVID-19 impact, retirements.

Whether the COA correctly disallowed the grant of the Cost Economy Measure Award (CEMA).
Whether petitioners should be excused from returning the CEMA amounts they received.
Procedural issue on the authority of petitioners’ affiants to file and represent others in the petition.