Case Summary (G.R. No. 252035)
Applicable Law and Background
The events in question are rooted in a directive from then-President Gloria Macapagal Arroyo in 2002 to implement pricing incentives for large electricity users. Consequently, ERC launched SPEED, allowing discounts of up to P0.80/kWh for qualified industrial users. However, complications arose when NPC failed to comply with the implementation timeline, initially issuing discounts late and consequently facing reprimands and directives from the ERC.
Procedural History
CAPASCO initially filed a petition with the COA seeking payment for a SPEED discount of P24,637,094.65—an amount established in prior ERC decisions and affirmed by the Court of Appeals in a separate case. The COA, however, denied the claim on the grounds that while CAPASCO was recognized as entitled to a refund, the precise amount was not detailed in the earlier decisions, and it questioned how the ERC calculated that sum.
COA's Denial of Money Claim
In its Decision No. 2018-256 dated March 15, 2018, the COA ruled against CAPASCO, stating there was no clear indication of the amount due from the ERC or how it arrived at P24,637,094.65. The commission denied a subsequent motion for reconsideration via En Banc Notice No. 2020-012 on February 12, 2020.
Petitioner's Arguments
CAPASCO's petition to the Court claims that COA acted with grave abuse of discretion by disregarding the finality of the Court of Appeals’ decision that effectively validated CAPASCO's claim for the discount. The petitioner insists that the decision is binding and COA was mandated to execute it.
Respondents' Counterarguments
NPC and COA contended rights to review monetary claims against the government, arguing that even if the Court of Appeals had recognized a monetary obligation, COA retained the authority to ensure claims were substantiated and legally permissible before ordering payments. PSALM, in turn, posited that it is liable to pay the amount because the obligation belonged to NPC.
Supreme Court's Ruling
The Supreme Court found merit in CAPASCO's arguments, emphasizing the binding nature of the final and executory decisions of the Court of Appeals, and highlighted that COA oversteppe
...continue readingCase Syllabus (G.R. No. 252035)
The Case
- This petition for certiorari challenges Decision No. 2018-256 dated March 15, 2018, and En Banc Notice No. 2020-012 dated February 12, 2020, issued by the Commission on Audit (COA).
- The first decision denied the monetary claim of petitioner Cathay Pacific Steel Corporation (CAPASCO) due to lack of merit.
- The second decision denied CAPASCO's motion for reconsideration.
Antecedents
- In the 2002 State of the Nation Address by then-President Gloria Macapagal Arroyo, a directive was issued to electric power producers and distributors to provide price incentives to large electricity consumers.
- This initiative aimed to optimize electricity usage and stimulate economic activity, leading to the establishment of the Special Program to Enhance Electricity Demand (SPEED) by the Energy Regulatory Commission (ERC).
- The SPEED program offered discounts of up to P0.80/kWh to eligible industrial consumers based on their incremental power consumption above a defined Customer Baseline Load (CBL).
- The respondent National Power Corporation (NPC) was tasked with implementing the SPEED program, effective October 26, 2002.
NPC's Implementation and Compliance Issues
- NPC requested a modification of the discount rate from P0.80/kWh to P0.50/kWh, which was granted by ERC, effective September 26, 2003.
- Subsequent investigations revealed that NPC did not implement the SPEED discounts in accordance with the established g