Case Summary (G.R. No. 248971)
Factual Background
In November 2010, the PCSO-LPDO authorized several monetary benefits, including a Christmas Bonus equivalent to three months' basic salary, a Weekly Draw Allowance, and various other allowances for employees. However, these payments were subjected to audit, which resulted in several Notices of Disallowance (NDs) issued on December 8, 2010, by an audit team, citing the lack of legal basis since the benefits in question were grounded solely on a Collective Negotiation Agreement (CNA) and did not have adequate support from applicable laws.
Procedural History
After failing to file a timely appeal against the NDs, PCSO sought reconsideration, which Assistant Commissioner Elizabeth Zosa initially granted, allowing further review. However, the COA Regional Director subsequently upheld the NDs. In an appeal to the COA Proper, the petition was ultimately dismissed, although reconsideration was granted, leading to a decision on the merits that affirmed the disallowance of the benefits.
Ruling of the Commission Proper
On April 7, 2017, the COA Proper published its decision confirming that the PCSO Board does not possess unrestricted authority to fix salaries and benefits. The COA stated that all monetary benefits must comply with pertinent civil service and compensation laws. Additionally, it rejected the petitioners' reliance on a purported post facto approval from the Office of the President, clarifying that such approvals cannot retroactively validate grants that contravene established laws.
Material Issues Presented
The key issues raised by the petitioners included assertions of wrongful dismissal of their review petition based on timeliness, claims of lawful authority to grant the allowances, reliance on post facto presidential approval, and compliance with the principle of non-diminution of benefits. Furthermore, they argued that they acted in good faith as approving officers in issuing the disallowed allowances.
Court's Analysis and Conclusion
The Court ultimately dismissed the petition, emphasizing respect for the COA's authority and expertise in enforcing audit regulations. It found no evidence of grave abuse of discretion in the COA's decisions. The Court reiterated that the PCSO Board’s powers over employee compensation are not absolute, fundamentally governed by existing civil service statutes and regulations. The various allowances, such as the Christmas Bonus and hazard pay, were deemed unlawful due to their integration into standardized salary rates, and without presidential approval, could not be separately dispensed.
Moreover, the Court rejected the petitioners' arguments concerning good faith, det
...continue readingCase Syllabus (G.R. No. 248971)
Case Background
- The petitioners, Philippine Charity Sweepstakes Office (PCSO) and Remeliza M. Gabuyo, filed a Petition for Certiorari under Rule 64 in relation to Rule 65 of the Rules of Court.
- The petition assails Decision No. 2017-084 dated April 7, 2017, and Resolution No. 2018-328 dated July 9, 2018, both from the Commission on Audit (COA) Proper.
- The COA Proper affirmed the disallowance of payments totaling P1,601,067.49 for various allowances granted to personnel of the Laguna Provincial District Office (LPDO) of PCSO, as per Notice of Disallowance (ND) Nos. PCSO 2010-16-101(2010), PCSO 2010-17-101(2010), and PCSO 2010-18-101(2010), all dated December 8, 2010.
Antecedents
- In November 2010, PCSO-LPDO granted monetary benefits to personnel, which were later audited by the COA.
- The audit led to the issuance of several NDs disallowing benefits based on lack of legal basis, citing that these were derived from the PCSO-Sweepstakes Employees Union (SEU) Collective Negotiation Agreement (CNA) and not from statutory authority.
- The benefits disallowed included:
- Christmas Bonus (P1,459,050.60)
- Weekly Draw Allowance (P40,200.00)
- Staple Food Allowance, Hazard Pay, Cost of Living Allowance (COLA), and Medicine Allowance (P101,816.89)
Procedural History
- Petitioners did not file an appeal on time, resulting in a Notice of Finality of Decision (NFD).
- They later sought reconsideration, claiming inadvertence and that the disallowed benefits had been approved post facto by the Office of the President.
- Assistant Commissioner Elizabeth Zosa granted a reconsideration, but the COA Regional Director upheld the NDs.
- Petitioners subsequently filed a petition f