Case Summary (G.R. No. 232199)
Applicable Law
This case is governed by the provisions of the 1987 Philippine Constitution, Republic Act No. 9136 (Electric Power Industry Reform Act of 2001 or EPIRA), and the various circulars and rules issued by the COA and other relevant governing laws.
Overview of the Case
TRANSCO filed a petition seeking relief from the COA’s Decision No. 2017-154 which upheld the COA's Notice of Disallowance TC-10-004(09). This notice disallowed part of Macapodi's separation benefits as it was deemed excessive under the law. The separation pay computation initially employed two multipliers, leading to a payment that exceeded what was legally allowed under EPIRA.
Legal Framework of Separation Benefits
The EPIRA stipulates that affected employees entitled to separation benefits shall receive "one and one-half month salary for every year of service" in calculating their separation pay. TRANSCO's Board of Directors was empowered to fix the compensation and allowances for its employees but must adhere to the guidelines set forth in EPIRA regarding separation benefits.
Implementation of Separation Pay
Pursuant to EPIRA, TRANSCO resolved to implement an Early Leavers Program to facilitate payments to separated employees. A circular issued by the president of TRANSCO modified the length of service computation, which inadvertently inflated the separation pay due to the incorrect application of multipliers.
COA's Findings
The COA Supervisor’s post-audit determined that the separation benefits disbursed to Macapodi were excessive, as the actual length of service used was inflated from about 42.97 years to 61 years by applying additional multipliers improperly. This led to the issuance of the Notice of Disallowance, which was subsequently affirmed by higher COA officials as lacking legal basis.
TRANSCO's Appeal and COA's Ruling
TRANSCO’s appeal was denied by COA Director IV Rufina S. Laquindanum, reiterating that additional multipliers beyond those provided for in EPIRA were unauthorized and led to overpayment. The COA Proper affirmed the disallowance and identified the approving and certifying officers as liable, but exempted Macapodi from refunding the excess amount.
Supreme Court's Assessment
Upon reviewing the COA's findings, the Supreme Court concluded that the payment to Macapodi was illegal due to its inconsistency with the computation mandated by EPIRA. Therefore, the overpayment was legally disallowed. The court ruled that Macapodi must return the excess payment as it was made in error.
Liability of Involved Parties
The Court clarified the liabilities of different individuals involved. Macapodi, as the recipient of the disallowed amount, was found liable under principles of unju
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Case Overview
- This case involves a Petition for Certiorari under Rule 65 filed by the National Transmission Corporation (TRANSCO) against the Commission on Audit (COA) and COA Chairperson Michael G. Aguinaldo.
- The petition challenges COA Decision No. 2017-154 dated May 18, 2017, which upheld Notice of Disallowance No. TC-10-004(09) dated June 16, 2010.
- The Notice disallowed the payment of excessive separation benefits to Mr. Sabdullah T. Macapodi amounting to ₱883,341.63.
Legal Background
- The Electric Power Industry Reform Act of 2001 (EPIRA) was enacted to reform the electric power industry, which includes four sectors: generation, transmission, distribution, and supply.
- EPIRA aimed to privatize the National Power Corporation (NPC) and established TRANSCO to manage the transmission assets.
- TRANSCO's Board of Directors was empowered to fix the compensation, allowances, and benefits of its employees.
Facts of the Case
- TRANSCO, under the EPIRA, implemented an Early Leavers Program to facilitate the payment of separation pay due to employees separated from service.
- A resolution established the formula for calculating separation pay, which included a basic salary, a 1.5 multiplier for years of service, and exemptions from taxes.
- Macapodi, a legal researcher at TRANSCO, received a separation payment of ₱2,988,618.75, calculated based on an inflated length of service (61 years) instead of his actual service (42.97 years).
- The COA later determine