Case Summary (G.R. No. 253117)
Applicable Law
The relevant legal framework for this case includes the following: the 1987 Philippine Constitution, Republic Act No. 6758 (Compensation and Position Classification Act of 1989), Presidential Decree No. 1445 (Government Auditing Code), and other pertinent regulations.
Background of the Dispute
The case arises from Notice of Disallowance (ND) issued by the COA against past meal allowances granted to MWSS-CO employees for calendar years 2012 and 2013 totaling approximately P8,173,730.00. The COA determined that the allowances exceeded the allowable amount set by the Corporate Operating Budget (COB) approved by the Department of Budget and Management (DBM) and asserted that non-incumbents were not entitled to any meal allowance. The petitioners contested the legality of these NDs, maintaining that the MWSS Board had the authority to approve such allowances.
Initial Ruling by COA Cluster Director
The COA Cluster Director upheld the NDs, asserting the absence of prior Presidential approval for the allowances as a violation of existing regulations. The director stated that the benefits mentioned in the Concession Agreements only applied to absorbed employees and dismissed strong claims about the continued benefits to current government employees under RA 6758.
Appeal to COA Proper
The petitioners elevated their appeal to the COA Proper, which eventually denied the petition for review due to delay in filing and lack of merit. It ruled that the NDs had become final and executory due to procedural lapses by the petitioners and reiterated the absence of legal basis for continued disbursement beyond established guidelines.
Issues Raised
The primary issue for resolution is whether the COA Proper committed grave abuse of discretion by denying the petitioners' appeal regarding the disallowances imposed.
Court's Ruling on Timeliness
The Court acknowledged that the petition was filed beyond the reglementary period. However, it decided to relax procedural rules in light of compelling circumstances, notably the ongoing pandemic, which hindered timely action by the petitioners.
Substantive Analysis and Findings
Upon reviewing substantive issues, the Court found that the COA did not gravely abuse its discretion in affirming the NDs. The authority of the MWSS Board was circumscribed by law under RA 6758, which integrated allowances into salaries and mandated Presidential approval for any additional benefits. The Court reiterated that the illegal continuation of meal allowances constituted an ultra vires act by MWSS officials, thus lacking validity.
Key Legal Principles
The ruling emphasized that former benefits could only be retained by incumbents in positions as of July 1, 1989, and amounts disbursed beyond the approved allowance were deemed excessive. Additionally, the requirement of Presidential approval was highlighted as a safeguard against arbitrary fiscal decisions by public agencies.
Liability of the Petitioners
Regarding liability for the disallowed amounts, the Court clarified the distinction between appr
...continue readingCase Syllabus (G.R. No. 253117)
Antecedents
- The petitioners are current and former employees of the Metropolitan Waterworks and Sewerage System - Corporate Office (MWSS-CO).
- In 2012 and 2013, these employees approved or received meal allowances based on resolutions from the MWSS Board of Trustees.
- The COA issued Notices of Disallowance (NDs) against these meal allowance payments, totaling P8,173,730.00 for the mentioned years.
- The NDs indicated that the meal allowances had no legal basis, as the paid amounts exceeded the P66.00 per month authorized in the Corporate Operating Budget (COB) approved by the Department of Budget and Management (DBM).
Notices of Disallowance Details
- Four NDs were issued, detailing disallowed amounts for meal allowances:
- ND No. 14-005-05-(12): P2,142,850.00 for incumbents in 2012.
- ND No. 14-006-05-(12): P2,033,200.00 for non-incumbents in 2012.
- ND No. 14-007-05-(13): P2,086,800.00 for incumbents in 2013.
- ND No. 14-008-05-(13): P1,910,880.00 for non-incumbents in 2013.
- COA clarified that only incumbents as of June 30, 1989 were entitled to the P66.00 allowance, while non-incumbents were not entitled to any allowance.
Appeal and COA Cluster Director's Ruling
- The petitioners appealed to the COA's Corporate Government Sector, arguing that the MWSS Board had the authority to grant such allowances under the MWSS Charter.
- They asserted that th