Title
Abejo vs. Commission on Audit
Case
G.R. No. 254570
Decision Date
Jun 29, 2021
ICAB's CNA Incentives disallowed for exceeding DBM limits; petitioner absolved from liability due to good faith, no gross negligence.

Case Summary (G.R. No. 254570)

Overview of the Case

The case revolves around a petition for certiorari filed by Bernadette Lourdes B. Abejo, who challenges the Commission on Audit (COA) Decision No. 2020-127, which required her and other officers of the ICAB to return a total of P236,500.00 in disallowed Collective Negotiation Agreement (CNA) Incentives for 2011. The incentives were deemed disallowed due to alleged violations of relevant DBM circulars regarding disbursement rules.

Background of ICAB's CNA Incentives

From 2008 to 2011, ICAB granted CNA Incentives to its employees based on the provisions of DBM Budget Circular No. 2006-1, which outlined that such incentives should only be paid once at the end of the fiscal year. However, in December 2011, DBM Circular No. 2011-5 was issued, establishing a limit of P25,000.00 per employee for the CNA Incentives. The payments made by ICAB were found to exceed this limit and were issued before the end of 2011, leading to a disallowance from the COA.

Findings of COA Audit

The COA audit team found that ICAB had made two payments of CNA Incentives within the same fiscal year and that these payments exceeded the set limit. The COA issued Notice of Disallowance No. 2012-002-101, deeming the excess incentive payments non-compliant with DBM circulars. Petitioner Abejo contended that the payments were made in good faith based on existing savings and that she was unaware of the implications of the new circular until it was posted online in January 2012.

Ruling of the COA

The COA upheld the Notice of Disallowance, asserting that the ICAB's actions violated the stipulations in DBM BC No. 2006-1, which required that CNA incentives be processed after the fiscal year-end. The COA rejected Abejo’s arguments concerning the timing of the circular's effectivity and noted her failure to comply with existing regulations.

Threshold Issues

The primary questions addressed included: (1) the validity of the disallowance of the CNA Incentives, (2) the solidary liability of Abejo as the approving authority, and (3) the personal liability of Abejo regarding the excess amount received.

Court's Ruling on Validity of Disallowance

The Court affirmed the COA's decision, agreeing that the CNA Incentives disbursed in excess of the stipulated limits and prior to the close of the fiscal year warranted disallowance. The approval of dual payments was seen as a clear breach of DBM regulations.

Solidary Liability of the Approving Authority

Despite affirming the disallowance, the Court clarified that Abejo was not solidarily liable to return the entire disallowed sums without evidence of bad faith or gross negligence. The Court referenced precedents, emphasizing that public officials acting in good faith and within the bounds of reasonable interpretation of guidelines are generally shielded from full liability.

Assessment of Gross Negligence

While the COA asserted that Abejo exhibited gross negligence by failing to adhere to the guidelines, the Court found no evidence supporting a claim of gross negligence or bad faith. It reasoned that structural ambiguities in the regulations at the time allowed for a reasonable interpretation of the guidelines by Abejo.

Interpretation of Rules on Return

Combining past rulings, the Court refined the rules regarding the return of disallowed payments. It

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