Case Summary (G.R. No. 218241)
Applicable Law
The case primarily applies provisions of the 1987 Philippine Constitution, the Revised Rules of Procedure of the Commission on Audit (RRPC), Republic Act No. 6758 regarding compensation and allowances, and various budget circulars and administrative orders issued by the Department of Budget and Management.
Background of the Case
The events leading to the dispute began when the Audit Team Leader of the COA issued several NDs on November 26, 2012, disallowing grocery allowances and year-end financial assistance granted by ACWD to its employees. The primary reasons for these disallowances were the absence of legal bases for the allowances and prior rulings that deemed similar expenses as disallowed.
Procedural History
Petitioner Liwanag appealed these NDs, asserting that the audit team could not revisit benefits already reviewed in prior audits. The COA, however, affirmed these disallowances based on established rules, which led Liwanag to file a petition for review. The COA subsequently dismissed the appeal as being filed beyond the reglementary period, prompting this recourse to the Supreme Court.
Issues Presented
The Supreme Court was tasked with resolving several issues, including whether the COA abused its discretion by ruling that ACWD’s petition was filed out of time, and whether the disallowance of the benefits was proper under the law.
Timeliness of the Appeal
The Court found merit in the petitioner’s argument that his appeal was timely filed. It affirmed that since there was an increase in the disallowed amounts, the matter was subject to automatic review by the COA Proper, which prevented the prior decisions from becoming final.
Authority to File the Recourse
Despite the respondent's claims that Liwanag lacked authority to pursue this recourse, the Supreme Court clarified that the Board of Directors of ACWD had sufficient authority to permit Liwanag to file the necessary legal actions on behalf of the agency, invoking the principle that the General Manager is inherently authorized to act in such matters.
Justification of Disallowance
The COA determined that the disallowance was justified, citing that the grocery allowance and year-end financial assistance were not exempted under Section 12 of R.A. No. 6758, which consolidates allowances into standardized salaries. The petitioner contended that the allowances were part of established practices and thus should continue.
Compliance with Audit Guidelines
The Supreme Court found tha
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The Case
- The petitioner, Engr. Reynaldo C. Liwanag, as the General Manager of ACWD, challenges the COA's Decision No. 2015-046 dated February 23, 2015.
- The decision affirms several Notices of Disallowance (NDs) issued on November 26, 2012, regarding ACWD's distribution of grocery allowances and year-end financial assistance totaling P14,556,195.00 for 2008 and 2009.
Antecedents
- Notices of Disallowance Nos. 2012-003-101 (2008), 2012-004-101 (2008), 2012-005-101 (2009), and 2012-006-101 (2009) were issued by the COA's Audit Team Leader, citing the absence of legal basis for the allowances.
- Previous disallowances for similar benefits in 2010-2011 were affirmed in COA Region III Decision No. 2012-25.
- The disallowances were appealed by Liwanag, arguing that previous audits had cleared the allowances and that the COA's NDs contravened the non-diminution of benefits principle.
Procedural History
- Following the appeal filed on May 28, 2013, the Regional Director denied the appeal via Decision No. 2013-91 dated September 18, 2013.
- Liwanag subsequently filed a petition for review with the COA Proper on