Title
Ramiscal vs. Commission on Audit
Case
G.R. No. 213716
Decision Date
Oct 10, 2017
Jose Ramiscal challenged COA's disallowance of AFP-RSBS land purchase irregularities; SC upheld COA but excluded his tax liability.

Case Summary (G.R. No. 213716)

Applicable Law

  • Philippine Constitution (1987), Article IX-D
  • Civil Code of the Philippines, Articles 1149, 1153, and 1108
  • Presidential Decree No. 1445

Overview of the Case

This case arose from allegations of fraudulent financial transactions involving land acquisitions by the AFP-RSBS. The COA discovered discrepancies related to the purchase price of properties in Calamba, Laguna, leading to a considerable loss of government funds. The petitioner, Jose S. Ramiscal, argued against a Notice of Disallowance (ND) and a Notice of Charge (NC) issued against him, asserting that the claims were barred by prescription, COA lacked jurisdiction, and his resignation precluded further proceedings.

Background of Allegations

In response to concerns raised during congressional investigations, the COA initiated an audit of transactions involving the AFP-RSBS. It was found that Ramiscal, acting for the AFP-RSBS, approved a land purchase from Concord Resources, Inc. for P341,343,000, despite a recorded sale price of only P91,024,800, leading to substantial financial discrepancies impacting tax liabilities.

COA Findings

The COA's special audit team concluded that the AFP-RSBS had overpaid by P250,318,200 based on the inflated purchase price and highlighted failures to properly report capital gains and documentary stamp taxes, resulting in significant underpayment.

Preliminary Actions and Proceedings

The audit findings resulted in the issuance of ND No. 2010-07-084-(1996) and NC No. 2010-07-001-(1996) in 2010, directing Ramiscal and others to settle the amounts. Ramiscal's appeals to COA were denied, prompting him to seek judicial review.

Jurisdictional Arguments

Ramiscal argued that the COA's actions were time-barred under the Civil Code’s provisions on prescription. However, it was determined that the State’s right to recover public funds does not prescribe, as enshrined in Article 1108 of the Civil Code, which states that prescription does not run against the State.

Accrual of Cause of Action

The Supreme Court clarified that the COA's cause of action only accrued upon the request from the Ombudsman in 2004, therefore the issuance of ND and NC in 2010 fell within the permissible time frame.

Liability Post-Resignation

Ramiscal contended that he could not be subjected to COA proceedings due to his resignation and the pendency of criminal cases. The Court reaffirmed the threefold liability rule, distinguishing between civil, administrative, and criminal accountability, allowing for continued civil and administrative actions even post-resignation.

Jurisdiction Over National Revenue Taxes

The argument that COA lacked jurisdiction over tax matters was partially upheld. While COA could audit an

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.