Title
Madera vs. Commission on Audit
Case
G.R. No. 244128
Decision Date
Sep 8, 2020
Municipality of Mondragon granted unauthorized allowances in 2013, violating Salary Standardization Law. COA disallowed payments; SC upheld, exempting good-faith recipients from refund.

Case Summary (G.R. No. 176492)

Key Dates and Procedural Posture

Ordinances/resolutions and payments: December 2013. Notices of Disallowance (eleven NDs): dated February 20, 2014. COA Regional Director Decision: July 14, 2015 (affirming NDs). COA Proper Decision: December 27, 2017 (affirmed with modification excusing recipient-payees in good faith). Motion for Reconsideration denied: August 16, 2018; notice received November 12, 2018. Petition for certiorari filed January 11, 2019. Supreme Court disposition: petition partially granted; COA Decision affirmed with modification that petitioners need not refund the disallowed amount.

Applicable Law and Legal Framework

Constitutional and statutory basis applied: 1987 Philippine Constitution (given decision date >1990), Local Government Code (R.A. 7160), Salary Standardization Law (R.A. 6758, Section 12), Administrative Code of 1987 (EO No. 292), Government Auditing Code (PD 1445), Budget Reform Decree (PD 1177), COA circulars and COA Rules (COA Circulars Nos. 2013-003, 2009-006, 94-001; Manual on Certificate of Settlement and Balances), and related jurisprudence addressing disallowances, solutio indebiti, and unjust enrichment.

Factual Background — Allowances and Beneficiaries

The Municipality granted: Economic Crisis Assistance (ECA), Monetary Augmentation of Municipal Agency (MAMA), Agricultural Crisis Assistance (ACA), and Mitigation Allowance to Municipal Employees (MAME). Recipients included regular, casual and job order/contractual municipal employees, barangay workers (tanods, BNS, DCW, BHW), public elementary and high school teachers, and national employees assigned to the municipality. The SB resolutions framed the grants as financial assistance in response to inflation, high interest loans, agricultural shortages after Typhoon Yolanda, and disaster mitigation needs.

Notices of Disallowance — Grounds and Persons Charged

COA Audit Team issued eleven NDs (Feb. 20, 2014) disallowing the subject allowances amounting to P7,706,253.10. Grounds: (a) violation of Section 12, R.A. 6758 (consolidation of allowances into standardized salary rates); (b) not authorized under COA Circular No. 2013-003’s list of authorized allowances; (c) inapplicability of benefits to contract/job-order personnel under CSC Resolution No. 02-0790. Persons charged included the municipal approving and certifying officers (Mayor, Municipal Accountant, Treasurer, Budget Officer) for their respective certification/approval roles and all payees as claimants/recipients.

Administrative Review — COA Regional Director Ruling

On appeal to the COA Regional Director, the RD (July 14, 2015) affirmed the NDs. The RD held the municipality’s authority under Section 447(a)(1)(viii) of R.A. 7160 could not override Section 12 of R.A. 6758; the appropriation ordinance was insufficient legal basis; the LGC did not repeal Section 12 of R.A. 6758; custom did not validate an otherwise illegal grant; the ordinance and resolutions were not shown to have been transmitted to the Sangguniang Panlalawigan for review under Section 327, R.A. 7160; and appropriations from savings/unappropriated balances violated Section 322, R.A. 7160.

COA Proper Decision and Modification

COA Proper (Dec. 27, 2017) affirmed the disallowances but modified liability: approving officers who passed and approved the ordinance/resolutions and those who certified/approved payments were ordered to refund the entire disallowed benefits; however, officials and employees who unwittingly received the disallowed benefits were excused from reimbursement as recipient-payees in good faith. COA acknowledged the inequity of making approving officers shoulder the full burden and the tension with solutio indebiti and unjust enrichment but applied the exception recognizing passive recipients in good faith based on existing jurisprudence.

Issue Before the Supreme Court

Whether COA committed grave abuse of discretion in affirming the NDs and in imposing liability on petitioners to refund disallowed amounts — and specifically whether petitioners could be held personally liable given their asserted good faith in approving the disbursements.

Timeliness and Court’s Discretion to Hear the Petition

Petition was filed late because Rule 64 prescribes 30 days from notice of COA decision (interruptible by MR). The petition arrived 35 days after the last day to file. The Court nonetheless exercised liberal application of procedural rules to address substantial issues and to harmonize conflicting jurisprudence on refund liability, invoking its role to prevent inequitable outcomes and to clarify rules for future cases.

Propriety of the Disallowances — Court’s Conclusion

The Court upheld the COA’s disallowances. The allowances were not authorized under R.A. 6758 and COA Circular No. 2013-003; they were not validated by sufficient legal basis; and the grant could not be justified merely as a gesture of gratitude. The Court quoted Section 447, R.A. 7160 (compensation-setting power) but held it could not prevail over Section 12 of R.A. 6758. Prior jurisprudence (e.g., Luciano Veloso) supports the limitation that additional allowances must be necessary or relevant to official duties, which was not demonstrated.

Civil, Administrative and Criminal Liability Framework

The Court reiterated statutory bases (PD 1177, PD 1445, Administrative Code, COA circulars) establishing that unlawful expenditures give rise to civil liability to refund, and that approving/certifying officers have supervisory responsibilities. Sections 38–39 (Administrative Code) require a clear showing of bad faith, malice, or gross negligence before holding public officers civilly liable for acts done in performance of official duties; Section 43 prescribes joint and several (solidary) liability for illegal expenditures. COA rules define liability and prescribe civil enforcement procedures (withholding, referral to OSG, etc.).

Badges of Good Faith for Approving/Certifying Officers

Adopting Justice Leonen’s proposed factors, the Court set illustrative "badges" to assess whether an authorizing officer exercised the diligence of a good father of a family: (1) certificate of availability of funds under Section 40 (Administrative Code); (2) in-house or DOJ legal opinion; (3) absence of precedent disallowing similar cases; (4) long-standing institutional practice without prior disallowance; (5) a reasonable textual interpretation of legality. Presence of such factors tends to uphold the presumption of good faith and may exculpate approving/certifying officers from civil liability.

Jurisprudential Treatment of Good Faith and Payee Liability

The Court reviewed cases: Blaquera (1998) excused return by good-faith parties; NEA (2002) imposed solidarity liability where officials blatantly violated directives; Casal (2006), MIAA (2012), TESDA (2014), Silang (2015), and others reflect evolving approaches distinguishing approving officers and passive recipients and varying the extent of refund. The Court recognized inconsistent outcomes and the need to harmonize rules, noting concern that excusing passive recipients can unfairly shift the entire burden to approving officers and may conflict with solutio indebiti and unjust enrichment principles.

Civil Principles — Solutio Indebiti and Unjust Enrichment Applied to Payees

The Court explained that payees’ liability is grounded in civil law principles (solutio indebiti, unjust enrichment under Article 22 and Article 2154 Civil Code): where funds were received without legal basis, even if by mistake and in good faith, the obligation to return generally arises. Exceptions exist where disallowed amounts were genuinely paid in consideration for services rendered (e.g., legitimate performance incentives) or

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