Title
Social Security System vs. Commission on Audit
Case
G.R. No. 243278
Decision Date
Nov 3, 2020
SSS disbursed excess benefits without Presidential approval; COA disallowed P335M. SC upheld disallowance but excused officers and recipients due to good faith, citing lack of malice.
A

Case Summary (G.R. No. 152302)

Applicable Law

The governing laws include the 1987 Philippine Constitution regarding the separation of powers and executive control, various statutes such as Presidential Decree No. 1597, and pertinent memoranda dictating that allowances and benefits for government personnel are subject to the approval of the President. Specific citations include Sections 5 and 6 of P.D. 1597, Joint Resolution No. 4, s. 2009, and Memorandum Order No. 20, s. 2001.

Facts Leading to Disallowance

The SSS initially proposed a COB of ₱5,384,737,000.00 for Personal Services, which was later reduced by the Department of Budget and Management (DBM) to ₱4,934,200,000.00. Notwithstanding this reduction, the SSS proceeded to disburse a total of ₱554,109,362.03 during 2010 for various benefits and allowances. Following an audit, it was found that ₱335,594,362.03 of these payments exceeded the approved COB, prompting the issuance of several NDs, including ND No. 2012-07 for the SSS NCR branches.

Appeal and COA Proceedings

Challenged by the SSS, the COA Corporate Government Sector Cluster 2 (COA CGS-2) denied the petition, stating that while GOCCs like the SSS may be exempt from the Salary Standardization Law (SSL), they remain under the supervision of the President through the DBM in matters concerning benefit grants. This led to a further appeal to the COA Commission Proper (COA-CP), which affirmed the COA CGS-2 decision with modifications that established certain liability exemptions for passive payees.

Court's Analysis on COA Decision

The SSS contended that the COA-CP acted with grave abuse of discretion, maintaining that its officials were authorized under the Social Security Law to determine compensation without requiring Presidential approval. However, the Court emphasized that the power granted to the SSS to set compensation does not exempt it from the prescribed approval requirements; thus, the COA's findings were appropriate.

Good Faith Defense and Circumstantial Evidence

The Court acknowledged potential exemptions from liability based on good faith. The SSS officers acted under the belief that their actions conformed to prevailing laws and interpretations at the time, particularly given the lack of clear legal precedents guiding their understanding of compliance requirements. The delay in DBM's response to the

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