Case Summary (G.R. No. 219157)
Background and Anatomization of Events
In December 1998, NFA Administrator Eduardo Nonato Joson sought presidential approval from then-President Joseph Estrada for a food assistance allowance, which was granted for a single Christmas season. In subsequent years, under President Gloria Macapagal-Arroyo, modifications were made regarding employee bonuses, culminating in the NFA Council’s approval, on May 18, 2005, to grant an annual FGI incentive to NFA employees. However, following multiple audits by the COA, several notices of disallowance were issued against these payments. The specific notices in question included ND No. 11-003-GOF(10) for the year 2010 and ND No. 2014-01(12) for 2012.
Legal Basis for Disallowance
Both notices cited violations of applicable laws, including the Compensation and Position Classification Act of 1989 (Republic Act No. 6758), the General Appropriations Act of 2010, and various Department of Budget and Management Circulars, which delineate the conditions under which incentives may be legally granted. The COA ruled that the FGI did not have legal authorization from the president, which was a prerequisite for its continuation.
Rulings of the COA
The COA upheld the disallowance on the grounds that the benefits were unauthorized and that the evidence presented by the petitioners indicating good faith was insufficient. Notably, the COA pointed out that the historical context of the FGI payments failed to demonstrate compliance with legislative requirements, thus asserting that previous presidential approvals were specific to individual instances and not indicative of ongoing authority.
Issues Presented by the Petitioners
The petitioners argued that the FGI had been traditionally awarded and was sanctioned by the “presidential imprimatur.” This claim also invoked equity principles. Ultimately, they contested the COA’s authority to disallow the payments based on their historical context and alleged good faith in administering the incentives.
Court's Analysis of COA's Rulings
The Supreme Court found no grave abuse of discretion by COA in its rulings. The Court emphasized that the burden of proof of grave abuse lies with the petitioners, and their failure to show such abuse affirmed the COA's decisions. The Court also reiterated the principle of res judicata, having been previously established in Escarez v. Commission on Audit, which ruled that similar disallowances were upheld on the same grounds in earlier cases.
Finding on Presidential Authority and FGI Legality
The Supreme Court underscored that the previous presidential approval related specifically to the food assistance allocated for the 1998 Christmas season and did not extend to sustained annual incentives. Furthermore, the Court maintained that any understanding of authority based on historical practice did not withstand legal scrutiny under Republic Act No. 6758.
Liability for Return of Disallowed Funds
Concerning the civil liability of both approving officers and reci
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Case Background
Parties Involved:
- Petitioners: Miguel C. Wycoo (Former Regional Manager of National Food Authority - Zamboanga Regional Office), Aracely C. Valledor, and all concerned NFA Region IX employees.
- Respondents: Milagros L. Aquino (Audit Team Leader), Estrella B. Avila (Supervising Auditor), and Nilda B. Plaras (Director IV, COA).
Case Numbers:
- G.R. No. 237874 and G.R. No. 239036, consolidated petitions for certiorari under Rule 64 in relation to Rule 65 of the Rules of Court.
Key Issues:
- The propriety of the Notice of Disallowance (ND) regarding the Food and Grocery Incentive (FGI) granted by the NFA to its employees for specific calendar years.
- Legal basis for the grant of benefits and potential liability for refunding disallowed amounts.
Antecedents
Historical Context:
- In December 1998, NFA Administrator Eduardo Nonato Joson requested approval from President Joseph Estrada for a food assistance allowance of Php7,000 for NFA employees, which was granted.
- In 2003, Secretary Ricardo Saludo issued a memorandum urging moderation in granting bonuses, prompting NFA Administrator Arthur Y. Yap to seek legal opinion from the OGCC regarding the FGI.
Subsequent Developments:
- OGCC issued Opinion No. 21910 in November 2003, affirming the authority of NFA to grant Christmas bonuses.
- The NFA Council passed Resolution No. 226-2K5 in May 2005, authorizing annual FGI grants of Php20,000, payable in two tranches.
Disallowances Issued by COA:
- In G.R. No. 237874, ND No. 11-003-GOF(10) disallowed Php660,000.00 granted for CY 2010.
- In G.R. No. 239036, ND No. 2014-01(12) disallowed Php480