Case Summary (G.R. No. 195105)
Applicable Law
The decisions related to this case draw upon the provisions set forth in the 1987 Philippine Constitution and Republic Act No. 6758, known as the Compensation and Position Classification Act of 1989. The law governs the standardization of compensation and allowances within government agencies, mandating adherence to formal procedures for the approval of benefits.
Background
Prior to the enactment of R.A. No. 6758, MWSS's Board of Trustees granted various employee benefits over the years. However, post-enactment, a Notice of Disallowance issued by Lakambini Q. Razon, the Resident Auditor, declared these benefits disallowed due to non-compliance with R.A. No. 6758. COA subsequently affirmed these disallowances, leading to an obligation for MWSS officers to refund the amounts.
Legal Proceedings
The MWSS challenged COA's disallowances, arguing that the benefits were validly established and did not contravene existing laws, including asserting that R.A. No. 6758 did not affect their authority under their corporate charter. These arguments were denied by the COA, leading to G.R. No. 195105, which involved the appeal of audit disallowances, and G.R. No. 220729, seeking to set aside COA Order of Execution No. 2015-174 identifying specific MWSS officials as personally liable for refunds.
Issues Presented
The cases raised fundamental legal questions: Whether COA acted with grave abuse of discretion in affirming the disallowances and whether the MWSS officials were personally liable to refund disallowed amounts, given their lack of direct participation in approving the benefits.
Court Rulings
The Supreme Court concluded that COA did not gravely abuse its discretion in issuing the notices of disallowance against MWSS. However, it found the MWSS officials not personally liable for refunding the disallowed benefits since they lacked participation in the decision-making that led to the approval of these benefits. The responsibility for the illegal disbursements lay with the Board of Trustees, not the individual officials who carried out daily operations.
Application of Law
The Supreme Court emphasized that the repeal of prior laws by R.A. No. 6758 rendered any actions taken by the MWSS's Board of Trustees that contradicted the new l
...continue readingCase Syllabus (G.R. No. 195105)
Case Overview
- The case involves two petitions: G.R. No. 195105 and G.R. No. 220729.
- Petitioner in G.R. No. 195105: Metropolitan Waterworks and Sewerage System (MWSS).
- Respondent: Commission on Audit (COA).
- Petitioners in G.R. No. 220729: Darlina T. Uy, Leonor C. Cleofas, Ma. Lourdes R. Naz, Jocelyn M. Toledo, Loida G. Ceguerra, and Miriam S. Fulgueras.
- The central issue is the disallowance of certain benefits received by MWSS employees and the personal liability of the petitioners for refunding these amounts.
Background of the Case
- Prior to Republic Act No. 6758 (R.A. No. 6758), MWSS's Board of Trustees approved various employee benefits over time.
- Included benefits: mid-year financial assistance, bigay-pala (anniversary bonus), meal/medical allowance, productivity bonus, year-end financial assistance, and longevity pay.
- R.A. No. 6758 was enacted to standardize salaries and benefits for government employees, repealing previous exemptions for certain agencies.
- Following the enactment of R.A. No. 6758, COA issued Notices of Disallowance (ND) for benefits paid to MWSS employees between January 2000 and November 2000.
Events Leading to Disallowance
- Various NDs were issued disallowing specific amounts:
- Mid-Year FA: P2,128,780.40
- Year-End FA: P1,929,610.60
- Bigay-Pala Anniversary Bonus: P742,573.90
- Productivity Incentive Bonus: P2,147,432.60
- Medical Allowance: P235,000.00
- Representation and Transportation Allowance (RATA): P155