Case Summary (G.R. No. 210940)
Antecedents of the Case
On May 14, 1997, the Social Security Commission approved Resolution No. 360, which introduced a new compensation package for its members, covering medical benefits, rice allowance, and a provident fund. Subsequently, on September 22, 1999, the Commission issued Resolution No. 790, permitting EME similar to those provided to members of the Government Service Insurance System (GSIS). In 2007, the COA disallowed the disbursements made under these resolutions, citing lack of legal authority for the SSC Commissioners to claim these allowances under the SSS Charter and the General Appropriations Act.
Basis for Disallowance
The COA's grounds for the disallowance were twofold. Firstly, it stated that the SSC Commissioners lacked the legal authority to claim EME as the General Appropriations Act does not provide for such claims by members of boards of directors. Secondly, the medical expenses, rice allowances, and provident funds were deemed not applicable as only rank-and-file employees of Government-Owned and Controlled Corporations (GOCCs) are entitled to such benefits under existing labor agreements.
Motion for Reconsideration by SSS
In response to the disallowance, the SSS filed for reconsideration, contending that while there was no explicit provision in the SSS Charter allowing EME, the authority was sufficiently supported by other provisions within the same law. They argued that their fiscal autonomy negated the need for compliance with the General Appropriations Act, allowing them to manage their budget and fund allocations independently.
COA Legal Services Sector's Ruling
On August 10, 2009, the COA Legal Services Sector denied the SSS's motion for reconsideration, reiterating that the SSC was bound by COA Circular No. 2006-001, which established guidelines for EME disbursements in GOCCs. The legal services also asserted that the SSC members could not receive allowances beyond those specifically enumerated in the SSS law.
COA's Affirmation of Disallowance
The COA, in its decision issued on January 30, 2013, upheld the disallowance, explaining that the SSS law did not grant the SSC the authority to fix compensation, allowances, and other benefits outside of what was prescribed in Section 3 of the Social Security Law. The Commission ruled that the alleged additional benefits were not legal, as they were not explicitly enumerated in the law.
Sole Legal Issue Presented
The core issue presented for the Supreme Court’s resolution was whether the SSC members were entitled to receive the EME, medical benefits, rice allowance, and provident fund. The SSS maintained that the powers granted by the Social Security Law gave them grounds to provide such benefits independently of the General Appropriations Act.
Court's Ruling on Authority and Compensation
Upon review, the Court affirmed the COA's position, reinforcing that the Social Security Law clearly delineated the benefits allowable for SSC members. The Court highlighted the principle of expressio unius est exclusio alterius, stating that where specific allowances are enumerated, no additional benefits outside those listed are permissible. The Court concluded that the existing law served to provide reasonable compensation, and the SSC could not unilaterally extend their benefits under the claimed fiscal autonomy.
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Introduction
- This case involves a petition for review on certiorari filed under Rule 64 of the Rules of Court.
- The petitioner, the Social Security System (SSS), seeks to reverse the January 30, 2013 Decision and the December 6, 2013 Resolution of the Commission on Audit (COA).
- The COA's decisions affirmed Notice of Disallowance (ND) No. SSS-2207-02 (2004), which disallowed P4,314,683.99 spent on Extraordinary and Miscellaneous Expenses (EME), medical expenses, rice allowance, and provident fund benefits for members of the Social Security Commission (SSC).
Antecedents
- On May 14, 1997, the SSC approved Resolution No. 360, which granted a new compensation package including medical benefits, rice allowance, and a provident fund to its members.
- On September 22, 1999, the SSC issued Resolution No. 790, which included provisions for EME similar to those provided for members of the Government Service Insurance System (GSIS).
- In 2007, COA issued ND No. SSS-2007-02 (2004), disallowing a total of P4,314,683.99, which included:
- P3,877,199.96 for EME
- P70,992.03 for medical benefits
- P106,992.00 for rice benefits
- P259,500.00 for the provident fund
- The disallowance was based on the following grounds:
- Lack of legal authority for SSC Commissioners to claim EME under the SSS Charter and the General Appropriations Act (GAA).
- Medical expenses, rice allowances, and provident funds were disallowed as they were not entitled to members of the Commission under the applicable laws.
Motion for Reconsideration
- The SSS filed a Motion for Reconsideration, arguing:
- The SSC had the authority t