Case Summary (G.R. No. 199114)
Relevant Facts and Background
Leonel Labrador was dismissed from his position on May 2, 1997, following a finding by then Labor Secretary Leonardo A. Quisumbing that he had engaged in bribery. This dismissal was later affirmed by the Civil Service Commission (CSC) and subsequently upheld by the Sandiganbayan. During a prolonged legal process, which included a conviction and sentencing for bribery, Labrador applied for probation, which was erroneously granted despite his disqualification from public office. Dimapilis-Baldoz, acting on the belief that Labrador was still employed, approved payments for his salaries and benefits from August 31, 1999, until March 15, 2004, the date of his formal separation from service.
Incident and COA Findings
On February 7, 2005, the COA issued an Audit Observation Memorandum noting that salaries and benefits paid to Labrador during the aforementioned period were unwarranted given his prior conviction and dismissal. Consequently, on January 18, 2006, the COA issued a Notice of Disallowance, finding Dimapilis-Baldoz personally liable for the total amount of P1,740,124.08, asserting that the payments made were illegal and therefore must be refunded. Dimapilis-Baldoz contested this, claiming she had acted in good faith and was unaware of the underlying administrative and criminal findings against Labrador.
Legal Basis for COA Authority
The authority of the COA to audit and disallow improper disbursements is grounded in the 1987 Philippine Constitution, Article IX-D, which provides for the examination and settlement of accounts related to government revenue and expenditures. The COA's rulings reflect its duty to ensure accountability for government funds and to uphold integrity in public service, emphasizing the importance of preventing resources from being misused.
Court’s Ruling on Disallowance
The Court partially granted the petition, correcting the COA's reckoning of the disallowance. While the COA argued that disallowance should begin from May 3, 2000, the ruling established that the proper date is May 2, 1997, the date of Labrador's initial dismissal. The Court held that since his removal was executed immediately, he should not have received any further remuneration.
Dimapilis-Baldoz's Personal Liability
A crucial aspect of the ruling involved assessing Dimapilis-Baldoz's personal liability for the disallowed amounts. The Court noted that public officials are presumed to act in good faith unless proven otherwise. Since the records indicated she was not notified of the judicial and administrative proceedings reg
...continue readingCase Syllabus (G.R. No. 199114)
Case Citation
- 714 Phil. 171; 110 OG No. 17, 2645 (April 28, 2014) EN BANC [G.R. No. 199114, July 16, 2013]
Parties Involved
- Petitioner: Rosalinda Dimapilis-Baldoz, in her capacity as then Administrator of the Philippine Overseas Employment Administration (POEA)
- Respondent: Commission on Audit (COA), represented by Chairman Reynaldo A. Villar and Commissioner Juanito G. Espino, Jr.
Procedural Background
- The petition for certiorari assailed COA Decision No. 2009-121 dated October 29, 2009, which affirmed Notice of Disallowance No. 2006-002 dated January 18, 2006.
- The Notice directed Dimapilis-Baldoz to refund the amount of P1,740,124.08, representing salaries and benefits unduly received by Leonel P. Labrador after his dismissal from service.
Factual Background
Leonel P. Labrador's Dismissal:
- Dismissed on May 2, 1997, by Labor Secretary Leonardo A. Quisumbing for bribery involving an overseas employment certificate.
- Dismissal was affirmed by the Civil Service Commission (CSC) in 2003, with subsequent motions for reconsideration denied.
Criminal Case Against Labrador:
- Convicted of direct bribery by the Sandiganbayan on August 31, 1999, sentenced to imprisonment, and a fine, with temporary special disqualification from public office.
- The Court affirmed his conviction with finality, denying further motions for reconsideration.
Probation Grant:
- Labrador applied for probation in 2001, which was erroneously granted despite the disqualification from public office.
- The Sandiganbayan later retracte