Case Summary (G.R. No. 254394)

Background of the Case

• The case revolves around a Petition for Certiorari filed by Libertad O. Alameda, the Municipal Mayor, along with other municipal officials, against the Commission on Audit (COA).
• The petition challenges COA Decision No. 2018-350, which approved a Notice of Disallowance (ND) for the amount of P1,248,085.69 related to salaries and benefits paid to Dr. Edmund L. Lamela, the Municipal Health Officer (MHO) of San Agustin, Surigao del Sur.
• The petitioners also contest Resolution No. 2020-291, which denied their motion for reconsideration regarding the ND.

Appointment and Disallowance

• Dr. Lamela was appointed as MHO on September 11, 2012, under a temporary appointment valid for 12 months.
• Following the 2013 elections, Libertad O. Alameda became the new mayor and continued to perform her duties.
• On January 26, 2015, COA issued an ND covering payments made to Dr. Lamela from September 12, 2013, to December 31, 2014, identifying several officials, including Alameda and Municipal Accountant Maria Lourdes A. Navaja, as liable for the disallowed payments.

Petitioners' Appeal and COA's Initial Decision

• The petitioners appealed the ND, arguing that Dr. Lamela's continued service as MHO constituted a de facto appointment, thus entitling him to compensation.
• COA Regional Office No. XIII upheld the ND, stating there was no valid appointment for Dr. Lamela after his temporary appointment expired, and thus, the payments made were illegal.

COA's Rationale on Liability

• The COA found that the petitioners failed to exercise due diligence in verifying Dr. Lamela's appointment status before disbursing funds.
• It ruled that while Dr. Lamela provided valuable services, he could not be considered a de facto officer due to the lack of a valid appointment.
• The COA determined that the petitioners were liable for the disallowed payments due to negligence.

Petitioners' Motion for Reconsideration

• The petitioners filed a motion for reconsideration, which was denied by the COA.
• They subsequently filed a petition with the Supreme Court, alleging grave abuse of discretion by the COA in its findings and conclusions.

Procedural Issues Raised

• The petitioners contended that their right to due process was violated when the COA miscalculated the filing date of their motion for reconsideration.
• The Supreme Court noted that while the COA erred in determining the filing date, the petitioners were still afforded the opportunity to present their case, thus not violating due process.

Substantive Issues on De Facto Officer Status

• The core issue was whether Dr. Lamela could be classified as a de facto officer after his temporary appointment expired.
• The Court referenced the definition of a de facto officer, emphasizing that such status requires a de jure office, color of authority, and actual possession of the office in good faith.

COA's Misinterpretation of De Facto Officer Doctrine

• The COA concluded that Dr. Lamela lacked color of authority after his temporary appointment expired, failing to recognize the general acquiescence by the public regarding his role.
• The petitioners provided evidence of public recognition of Dr. Lamela's position, including appropriations and certificates of appreciation.

Court's Conclusion on Compensation

• The Supreme Court found that Dr. Lamela was indeed a de facto officer, entitled to compensation for services rendered.
• The Court ruled that the COA's order for the petitioners t...continue reading

Case Syllabus (G.R. No. 254394)

Background of the Case

• The case arises from a Petition for Certiorari with a request for a Writ of Preliminary Injunction and/or Temporary Restraining Order under Rule 64, in relation to Rule 65 of the Rules of Court.
• The petition challenges Decision No. 2018-350 dated October 3, 2018, issued by the Commission on Audit (COA), which approved Notice of Disallowance No. 15-001-101-(13&14) for the total amount of P1,248,085.69.
• The COA's decision identified various municipal officials, including the petitioners, as liable for disallowed expenses related to the salaries and benefits of Dr. Edmund L. Lamela, who served as Municipal Health Officer (MHO) without a valid appointment after his temporary appointment expired.

Facts of the Case

• Dr. Edmund L. Lamela was appointed as MHO on September 11, 2012, for a temporary period of 12 months, in accordance with the Administrative Code of 1987.
• Libertad O. Alameda was elected as the new mayor in 2013 and exercised her duties thereafter.
• A Notice of Disallowance was issued by the COA on January 26, 2015, disallowing payments made to Dr. Lamela from September 12, 2013, to December 31, 2014, due to the lack of a valid appointment.
• The COA identified Alameda, Municipal Accountant Maria Lourdes A. Navaja, Municipal Treasurer Julia R. Orcullo, Municipal Budget Officer Rosenda D. Lamela, and Administrative Officer IV Abundia P. Salinas as liable for approving and processing the payments.

Arguments of the Petitioners

• Petitioners argued that Dr. Lamela acted in a d...continue reading