Case Summary (G.R. No. 228795)
Factual Background
On March 12, 2010, during a bank run to withdraw P1,300,000.00 for payroll, the vehicle carrying Estelita, Lily, and Felix was attacked by armed robbers, resulting in the death of Lily and serious injury to Felix. Following this incident, Estelita reported the event and requested relief from accountability for the lost payroll money, citing her lack of fault in the robbery and adherence to operational protocols, even though no security escort was provided during the transaction.
Initial Determinations
The initial response from municipal authorities, including the mayor and audit team leader, recommended relief for Estelita due to positive identification of the assailants and the absence of her fault in the incident. However, the COA's Adjudication and Settlement Board later denied this request, emphasizing the necessity of a security escort due to the high amount of money involved in the transaction.
COA’s Ruling and Subsequent Appeals
The COA affirmed the Board's ruling on April 13, 2015, stating that a higher degree of precaution was required and finding Estelita and the estate of Lily solidarily liable for the loss. Estelita sought reconsideration, but it was denied as both late and lacking in merit. This led to the current petition for certiorari filed under Rule 64 of the Rules of Court challenging the COA's decision.
Legal Requirements for Timeliness
Under Section 3, Rule 64 of the Rules of Court, Estelita was required to file her petition within 30 days from notice of the COA's judgment. Discrepancies in her timeline negatively impacted the case, as she failed to provide exact dates for receiving the initial COA decision and for filing her reconsideration motion.
Determining Negligence
The ruling involves substantial evaluation of whether Estelita and Lily exercised diligence akin to that of a "good father of a family." The court analyzed the definition of negligence, observing that it must be assessed relative to the circumstances at hand. The conduct displayed by Estelita and Lily was deemed reasonable under what was ostensibly an unforeseen violent robbery.
Comparison with Precedent Cases
The court referentially cited previous cases, such as Hernandez v. Chairman, Commission on Audit, which established that a lack of foresight regarding security measures cann
...continue readingCase Syllabus (G.R. No. 228795)
Case Citation
- 891 Phil. 44; 119 OG No. 9, 1467 (February 27, 2023) EN BANC
- G.R. No. 228795 [Formerly UDK 15699], December 01, 2020
Parties Involved
- Petitioner: Estelita A. Angeles
- Respondents: Commission on Audit (COA) and COA-Adjudication and Settlement Board
Key Issue
- The main issue revolves around the propriety of the denial of Estelita Angeles's request for relief from accountability concerning lost payroll money following a violent robbery.
Antecedents
- On March 12, 2010, a group including cashier Lily De Jesus and revenue collection officer Estrelita Ramos withdrew P1,300,000.00 from the Land Bank of the Philippines.
- While returning to their office, they were ambushed by armed robbers, leading to the death of Lily and injuries to the driver, Felix Alcantara.
- Following the incident, Estelita informed the Audit Team and requested relief from accountability due to the unexpected nature of the robbery and the absence of her fault.
- The municipal mayor and Audit Team Leader supported her request, stating that the practice of conducting bank transactions without police escort was followed by previous officers.
COA’s Decision
- On May 30, 2012, the Adjudication and Settlement Board denied the request for relief, holding Estelita and Lily's estate jointly liable for the amount lost, emphasizing the necessity of a security escort given the substantial amount involved.
- Estelita appealed this decision, arguing that the robbery was unforeseen and that existing protocols were followed, including obtaining a travel pass.
COA’s Affirmation
- On April 13, 2015, COA denied Estelita's petition, emphasizing that a higher degree of caution was warranted for handling large sums of money, and that her actions fell short of the required diligence.