Title
Social Security System vs. Commission on Audit
Case
G.R. No. 231391
Decision Date
Jun 22, 2021
SSS paid Counterpart CNA Incentives to non-rank-and-file employees, disallowed by COA for violating AO 103. SC upheld disallowance, ruling payments unauthorized; recipients liable for reimbursement.

Case Summary (G.R. No. 253117)

Applicable Law and Antecedents

The primary legislative basis for the case includes Administrative Order No. 103 and Republic Act No. 1161, which governs the SSS and establishes the framework for compensation of its personnel. A significant resolution involved is Resolution No. 259, issued by the Social Security Commission (SSC) on July 6, 2005, which authorized the granting of CNA incentives to both ACCESS members and a differentiated category labeled as Counterpart CNA Incentives for certain SSS personnel, including those not in the negotiating unit.

Initial Disallowance by COA

The COA, specifically through Notice of Disallowance No. 2010-004, concluded that the payments of Counterpart CNA Incentives to non-rank and file employees contravened existing regulations, specifically citing Section 3(b) of AO 103, which mandates suspension of additional benefits unless specifically allowed under certain presidential issuances. The underlying reasoning refers to prior relevant resolutions that limit CNA Incentives strictly to rank and file employees.

Ruling of the COA Director

The COA's Director IV, Angelina B. Villanueva, upheld the disallowance in Decision No. 2012-15. She argued that the SSC's power to fix compensation does not exempt it from compliance with relevant administrative issuances. Additionally, she highlighted previous COA rulings indicating that Counterpart CNA Incentives paid to non-rank and file employees were clearly prohibited under existing laws, rules, and regulations.

Affirmation by COA Proper

The COA Proper affirmed the Director's decision in Decision No. 2015-280, thereby upholding the disallowance after finding no grave abuse of discretion. The court deliberated over whether the differentiated payments could be considered CNA Incentives or if they fell outside regulated allowances. The core of their ruling was that payments made lacked necessary executive approval and that the SSC should have adhered strictly to the regulations concerning disbursements.

Legal Arguments Presented

The SSS presented multiple arguments highlighting its belief in the legality of the pay structure. It posited that the Counterpart CNA Incentives were legitimately derived from its authority to set employee compensation under RA 1161, claimed misinterpretations of prior rulings on CNA Incentives applied to its specific context, and indicated that good faith should absolve individuals from personal liability for disallowed benefits.

Court's Ruling

Ultimately, the Supreme Court found that the arguments raised by the SSS were insufficient to overturn the COA's ruling. The court reaffirmed that despite the SSC's purported power to determine employee compensation, the authority must still operate within established regulatory frameworks, including obtaining necessary approvals for additional incentives. The disbursement in question was neither categorized as legitimate CNA Incentives nor sanctioned by requisite executive orders.

Liabilit

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