Case Summary (G.R. No. 205490)
Applicable Law
The relevant statutes for this case include Administrative Order No. 402 (AO 402) and Civil Service Commission (CSC) Memorandum Circular No. 33, which stipulate guidelines for the provision of health programs in government offices, particularly concerning medical check-ups.
Background of the Case
PSALM implemented various health programs under Board Resolutions that expanded its medical assistance program beyond the initial diagnostic benefits envisaged in AO 402, which only approved basic check-up procedures. Despite the program's alignment with AO 402, the COA issued Notices of Disallowance after finding that many granted benefits exceeded what was legally permissible.
Disallowance Findings
The COA found that PSALM's expansion of benefits to include reimbursements for prescription drugs, dental treatments, and additional services to dependents violated the provisions of AO 402, which solely supports employee health check-ups. This interpretation strictly adhered to the principle of ejusdem generis, wherein additional benefits must be similar to those explicitly mentioned.
The Court's Ruling
The court affirmed the COA's decisions stating that the expanded MABs lacked legal basis. The court determined that the prior disallowance of benefits under AO 402 should have prompted PSALM to cease further implementations. Furthermore, the court established that any benefits outside the scope of AO 402 were unauthorized, reaffirming the necessity of compliance with established budgets, which PSALM exceeded.
Liability of PSALM Officers and Employees
The court assessed the liability of PSALM's officers and employees for the unauthorized benefits granted. It found that while officers acted without malice, their lack of due diligence constituted gross negligence given the clear limitations set by AO 402. Hence, both the officers who approved the disallowed amounts and the employees who received payments were held jointly and sev
...continue readingCase Syllabus (G.R. No. 205490)
Case Overview
- Case involves two petitions by the Power Sector Assets and Liabilities Management Corporation (PSALM) against the Commission on Audit (COA) regarding the disallowance of Medical Assistance Benefits (MAB) for its officers and employees.
- The first petition (G.R. No. 205490) relates to the disallowance of the 2009 MAB amounting to P5,586,999.60.
- The second petition (G.R. No. 218177) concerns the disallowance of the 2008 MAB totaling P5,702,517.42, and a subsequent resolution denying PSALM's motion for reconsideration.
Background and Context
- PSALM, as a government-owned and controlled corporation (GOCC), implemented health programs for its employees following directives from the Civil Service Commission (CSC) and Administrative Order No. 402 (AO 402).
- AO 402 mandates that government agencies establish a medical check-up program for government employees, including free annual medical examinations.
- The health program initiated by PSALM included various medical examinations and treatments aimed at ensuring the health and efficiency of employees.
The Medical Assistance Benefits (MAB)
- MAB was expanded to include additional benefits, which were approved through several board resolutions over the years.
- The 2008 and 2009 MABs provided coverage for purchases of prescription drugs, reimbursement for emergency medical expenses, and extended benefits to employees’