Title
Biong vs. Commission on Audit
Case
G.R. No. 258510
Decision Date
May 28, 2024
Jess Christopher S. Biong challenged COA's disallowance of PhilHealth payments for office supplies due to lack of inspection. The court ruled in Biong's favor, finding COA acted with grave abuse of discretion and violated due process.

Case Summary (G.R. No. 258510)

Discovery of Theft, Internal Investigation, and Petitioner's Actions

On January 31, 2011, petitioner Biong discovered alleged thefts of inks/toners and falsification of SWSs within the GSU. He filed an Incident Report (February 22, 2011) describing missing deliveries (including deliveries by other suppliers) and recommended a formal investigation by PhilHealth’s Legal Office. Biong filed a Request for Relief from Accountability with the COA Audit Team (March 18, 2011). Records do not show the outcome of that relief request prior to subsequent COA disallowances.

COA Audit Findings Underlying the Notices of Disallowance

COA Audit Team issued ND No. 11-002-000(10) (July 5, 2011) and ND No. 11-003-000(10) (August 15, 2011) disallowing payments to Silicon Valley on grounds including: staggered/delayed deliveries (violation of a 15-calendar-day delivery stipulation in the POs), lack of IARs or inspection by an authorized inspector (citing Section 465 of COA Circular No. 368-91), reliance on alternative documents (certification by Biong, SWSs, MRSMI) in lieu of IARs, altered/padded SWSs, SWSs without end-user counterparts, issuances to unknown recipients, and unaccounted deliveries — with specific disallowed amounts itemized per PO. Silicon Valley as payee was not held liable under the NDs.

COA Regional Office No. III Decision (2012)

COA RO3 (Assistant Commissioner Encallado) affirmed the disallowances (COA RO3 Decision No. 2012-46, Oct. 4, 2012) but excluded one officer (Reyes) from liability for one ND. RO3 emphasized that, although the disallowances sprang from lack of IARs and supplier delay, the real concern was management of office supplies and the long delay (two to three years) in payment processing, which strengthened the finding of irregularities. RO3 held that petitioner Biong, as GSU Chief, should have ensured prompt inspection and failed to exercise due diligence in acceptance and custody. The decision was referred for automatic review by COA Proper.

COA Proper Decision (2019)

COA Proper (Decision No. 2019-040, March 21, 2019) approved RO3’s decision with modifications: it excluded several officials (Balog, Lumba, Mamawal, Quizon, Marbebe) from liability while affirming the NDs against others, including petitioner Biong and Mary Joy Cruz. COA Proper found that PhilHealth RO3 had a valid obligation to pay Silicon Valley (which supported exclusion of certain signatories) but held Biong liable for “apparent and consistent negligence” for failing to discover falsified SWSs and MRSMI that led to payment despite lack of supporting documents. A Notice of Finality (Nov. 17, 2021) was later issued.

Procedural Defect: Failure of Service and Due Process

The Supreme Court first found an invalid service to petitioner Biong: he was not served a copy of COA Proper Decision No. 2019-040 prior to issuance of the Notice of Finality, and only received a certified true copy on January 25, 2022, precluding timely filing of motions for reconsideration. This violated Section 7 of the 2009 Revised Rules of Procedure of the COA (which prescribes service of ND/NC/NS, orders, or decisions by personal service or registered mail). The COA’s failure to comply with its own rules amounted to grave abuse of discretion and deprived Biong of due process; on that basis the Notice of Finality had to be set aside.

Standard of Judicial Review Applied

The Court acknowledged the general deference given to COA findings of fact when supported by substantial evidence, but emphasized the Court’s authority under Section 1, Article VIII of the 1987 Constitution to review for grave abuse of discretion amounting to lack or excess of jurisdiction. The Court reiterated COA’s mandate to prevent irregular, unnecessary, excessive, or illegal expenditures, but stressed that a disallowance is warranted only where an expenditure falls within those anomalous categories at the time the expenditure is incurred.

Court’s Analysis: Irregular Expenditure — Burden and Timing of Irregularity

The Court held that for an expenditure to be deemed irregular, the deviation from established rules or standards must have occurred at the time the expenditure was incurred; irregularities that occur after the expenditure or are disconnected from the underlying transaction do not justify disallowance. The Court examined the three grounds COA cited (supplier delay, lack of IARs, falsified SWSs) and found none sufficient to sustain disallowance of payments to Silicon Valley.

Court’s Analysis: Delay in Delivery and Contractual Remedies

The 15-calendar-day delivery condition in the POs was characterized as a contractual stipulation rather than an established legal rule. Breach of that clause is a supplier default triggering contractual remedies (liquidated damages, penalties, or contract termination per procurement rules), not automatic audit disallowance. Because Silicon Valley ultimately delivered the items and paid contractually-applicable penalties (liquidated damages), the Court held that disallowance on account of delay was unwarranted.

Court’s Analysis: Lack of Inspection and the Role of Internal Rules

The Court treated the absence of IARs and the inspector’s nonperformance as internal procedural lapses of PhilHealth RO3. Citing precedent (Theo-Pam), the Court reasoned that internal rules and process flows, which do not implicate the supplier, may not be used to deny payment to a third-party supplier that actually delivered and whose invoices showed receipt by agency personnel. The sales invoices and evidence that PhilHealth personnel received the goods sufficed to obligate PhilHealth to pay the supplier despite internal compliance failures.

Court’s Analysis: Falsified SWSs and Causal Disconnect

Although falsification of SWSs is an irregularity, the Court emphasized that the falsification occurred after completion of the procurement transactions and was disconnected from the POs and payments to Silicon Valley. The supplies at issue were fungible; COA did not show a logical causal link establishing that the falsified SWSs concerned the goods delivered by Silicon Valley rather than goods delivered by other suppliers (Masangkay Computer Center, PC Worx). Holding Silicon Valley or converting the supplier’s payment into a disallowance based on post-transaction theft/falsification by agency personnel was arbitrary. The Court found COA’s decision to disallow payments and penalize agency officers for supply-management failures to be capricious in the absence of a demonstrated causal relationship.

Relief-from-Accountability and Measure of Liability for Stolen Property

The Court noted that, if petitioner Biong were to be held accountable for missing supplies, the measure of liability under the Government Auditing Code (Sections 73, 102, 104, 105) is limited to the money value of the loss, and relief from accountability procedures apply (Section 73). The Court therefore separated any potential liability for theft or loss from the present inquiry into whether the payments to Silicon Valley were irregular; resolution of Biong’s Request for Relief from Accountability would determine any monetary liability for stolen property.

Solutio Indebiti, Payee Liability, and COA’s Application

The Court explained that when a disbursement is declared illegal or irregular, a payee’s receipt is generally subjec

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