Title
Poblete vs. Commission on Audit
Case
G.R. No. 222810
Decision Date
Jul 11, 2023
Petitioners challenged COA's dismissal of their appeal for late filing of fees involving disallowed payments from prior years' projects. The Court upheld dismissal but in dissent, quantum meruit was urged to temper liabilities and remand the case.

Case Summary (G.R. No. 222810)

Applicable Law

The pertinent laws influencing this ruling include the Local Government Code (LGC), specifically Section 350, which mandates that all expenditures incurred during a fiscal year should be accounted for in that same year. Additional references include the Administrative Code of 1987, particularly Sections 46, 47, and 48, concerning appropriations before entering contracts and the consequent liabilities of officers involved in unlawful contracts.

Facts of the Case

On June 2, 2011, the COA issued 12 Notices of Disallowance totaling P2,891,558.31, linked to various municipal projects from the years 2004, 2006, and 2007 which were financed with the 2010 budget. The execution of these projects was declared invalid due to a lack of the necessary appropriations at the time of their execution. The petitioners appealed the disallowances but were ultimately found to have filed their Petition for Review beyond the allowable period as per the COA's rules.

Procedural Background

The COA Regional Office upheld the Notices of Disallowance through Decision No. 2013-19, concluding that the municipality’s projects were void due to improper budget allocation. The petitioners subsequently filed for a review, which the COA Proper dismissed on the grounds of lack of timely payment of required filing fees. The petitioners contended that their fees were paid later than expected but asserted that the running of the period for filing should have been suspended upon their filing.

Issues Raised by the Petitioners

The petitioners raised several arguments, claiming that the COA's decision dismissed their appeal with grave abuse of discretion, citing irregularities on the COA's part and asserting the principle of quantum meruit, arguing that the government should compensate for services rendered under invalid contracts. They also referenced the Arias Doctrine, which posits that the head of an office should not be held liable for decisions made in good faith.

Ruling of the Court

The Court upheld the COA’s ruling, stating that the appeal was indeed filed out of time, given that the payment of the necessary filing fees was made belatedly—over 200 days after the petitioners received the disallowances. The Court reaffirms that adherence to procedural rules serves to uphold the orderly administration of justice, and procedural lapses such as those committed by the petitioners cannot be overlooked.

Substantive Grounds of the Decision

Moreover, the Court examined the substantive legal implications of the funding discrepancies, determining that the petitioner’s actions violated not only Section 350 of the LGC but also sections of the Administrative Code, making th

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