Case Summary (G.R. No. L-33237)
Applicable Law
Republic Act No. 6758, also known as the Compensation and Position Classification Act of 1989, is relevant to this case, specifically Section 18, which prohibits COA officials and employees from receiving salaries, bonuses, allowances, or other emoluments from any government entity, local government unit, government-owned or controlled corporations (GOCCs), and government financial institutions, unless such payments are made directly by the COA out of its appropriations and contributions.
Background of the Case
Prior to the enactment of the Compensation and Position Classification Act, the gross monthly compensation of the petitioners included various allowances and benefits provided by their assigned GOCCs. However, following the implementation of R.A. No. 6758, these additional emoluments were not permitted, leading to a reduction in the petitioners' salaries. The petitioners argued that the interpretation of the law by the Chairman of the COA was erroneous and led to an unjust diminution of their compensation.
Legal Arguments of the Petitioners
The petitioners contended two primary issues: first, whether Section 18 of R.A. No. 6758 authorized the reduction of gross compensation received prior to the law's enactment; and second, whether the allowances they previously received were paid directly by the COA out of its appropriations as specified in the exception noted in the same law. They argued for affirmation on the second point, maintaining that their compensation had always been paid out of COA appropriations.
Legal Arguments of the Respondent
The respondent, through the Office of the Solicitor General, upheld the interpretation of the law as articulated in the COA's memorandum. It asserted that the petitioners were no longer entitled to the extra allowances as these were not guaranteed under the law and indicated that such additional payments had no legal basis. Furthermore, it was argued that the continued receipt of supplementary compensation could undermine the independence and integrity of the auditing functions of the COA.
Court's Analysis and Conclusion
The Supreme Court concluded that Section 18 of R.A. No. 6758 was intended to fortify the COA's independence and integrity by explicitly barring the reception of unauthorized emoluments. The Court deemed that any extra compensation received by the petitioners from the GOCCs did not constitute direct payments from COA's appropriations, thereby rendering their pri
...continue readingCase Syllabus (G.R. No. L-33237)
Case Overview
- The case involves a special civil action for certiorari with prohibition and mandamus filed by petitioners Roseo U. Tejada and Radito C. Ching against Hon. Eufemio C. Domingo, the Chairman of the Commission on Audit (COA).
- Petitioners seek to annul the interpretation and implementation of Republic Act No. 6758, specifically Section 18, which they assert is erroneous, arbitrary, wrongful, and illegal.
Legislative Context
- Republic Act No. 6758 is known as the Compensation and Position Classification Act of 1989, aimed at standardizing salaries and benefits across government entities.
- Section 18 prohibits COA officials and employees from receiving additional compensation from any government entity, local government unit, or government-owned or controlled corporations, except for compensation paid directly by COA.
Petitioners’ Background
- Roseo U. Tejada and Radito C. Ching are senior clerks assigned to the Philippine National Bank (PNB) and Central Bank (CB), respectively.
- Prior to the enactment of R.A. No. 6758, Tejada's gross monthly compensation was P3,673.20, while Ching's was P3,134.00; these included various allowances beyond their basic salary and cost of living allowance.
Changes Under Republic Act No. 6758
- Following the effectivity of R.A. No. 6758, the additional emoluments received by the petitioners were eliminated, resulting in a reduced monthly salary of P2,323.00.
- The law mandates that COA personnel must be comp