Case Summary (G.R. No. 169726)
Factual Background
Before 1996, Respondent Olivia D. Leones served as the Municipal Treasurer of Bacnotan, La Union, where she was entitled to representation and transportation allowance (RATA). In December 1996, she was reassigned to the Office of the Provincial Treasurer of La Union due to pending administrative cases against her. Following her reassignment, the Municipality of Bacnotan ceased RATA payments to her. After unsuccessful attempts for administrative resolution, Leones filed a mandamus suit in the Regional Trial Court to compel payment of her RATA. The trial court dismissed her petition for not exhausting administrative remedies, a decision subsequently affirmed by the Court of Appeals and final on June 30, 2003. In September 2003, Leones sought an opinion from the DBM, which acknowledged her entitlement to RATA only for the year 1999 under that year’s General Appropriation Act.
Court of Appeals Ruling
The Court of Appeals ruled in favor of Leones on May 24, 2005, granting her RATA for the duration of her reassignment. The appellate court classified RATA as part of her salary, which is protected under the rule against wage dimunition during reassignments. The court criticized the DBM’s reliance on General Appropriations Acts (GAAs) that required actual performance to receive RATA, noting that Leones's salary was sourced from the local budget rather than the national budget.
DBM's Position
The DBM contended that RATA does not constitute part of a salary but is an allowance contingent upon actual performance of duties. They argued that since Leones was not performing her functions in Bacnotan during her reassignment, she was not entitled to RATA, except for the year 1999, when no such condition was imposed.
Issue at Hand
The core issue addressed was whether Leones was entitled to receive RATA following her reassignment to the La Union treasurer’s office.
Court's Analysis and Ruling
The court established that while RATA is distinct from salary, the DBM's discontinuation of payment lacked a legal basis. The court noted that allowances like RATA are designed to cover unavoidable expenses incurred in official duties, and therefore, should not be unduly cut off due to reassignment. The court rejected the DBM's reasoning that local government officials are bound by national budgetary provisions, emphasizing the vertical structure of government that allows for local autonomy.
Furthermore, the court pointed out that pertinent provisions, including those established under the Local Government Code, affirm that local treasure
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Introduction to the Case
- This case involves a petition for review by the Department of Budget and Management (DBM) regarding the entitlement of Olivia D. Leones to representation and transportation allowance (RATA).
- The case was decided by the Supreme Court on March 18, 2010, under G.R. No. 169726.
Background Facts
- Olivia D. Leones served as the Municipal Treasurer of Bacnotan, La Union, prior to her reassignment in December 1996 to the Office of the Provincial Treasurer, La Union.
- Following her reassignment, the Municipality of Bacnotan ceased payment of her RATA, which she had received in her capacity as Municipal Treasurer.
- After attempting to seek administrative relief without success, Leones filed a mandamus suit against the DBM and the then Mayor of Bacnotan, Ma. Minda Fontanilla, in the Regional Trial Court, which was dismissed for non-exhaustion of administrative remedies.
- The Court of Appeals upheld the trial court's dismissal, resulting in the ruling becoming final on June 30, 2003.
- Leones later sought an opinion from the DBM Secretary regarding her entitlement to RATA. The DBM found her entitled to RATA only for 1999, citing the General Appropriation Act (GAA) for that year, which did not require actual performance of functions for receipt of RATA.
- Leones contested this opinion by filing a petition for certiorari with the Court of Appeals, arguing that the cessation of her RATA violated the rule on non-diminution of salary in cases of reassignment.
Court of Appeals Ruling
- On May 24, 2005, the Court of Appeals ruled in favor of Leones, stating she was entitled to RATA for the duration of her reassignment.
- The Court characterized RATA as part of her salary, thus subject to non-diminution rules during reassignment.
- The Court noted that the