PHILIPPINE HEALTH INSURANCE CORPORATION vs COMISSION OF AUDIT,

CHARIPERSON MICHAEL G AGUINALDO, DIRECTOR JOSEPH ANACAY and

SUPERVISING AUDITOR ELENA AGUSTIN.
G.R. NO. 222710 JULY 24, 2018
FACTS
This case is a special civil action for certiorari with prayer for TRO and WPI under Rule
64, in relation of Rule 65 of Ruled of Court, filed by PhilHealth, which seeks to annul
and set aside the decision and resolution affirming the Notice of Disallowance on the
payment of longevity pay to its officers and employees for the period of January to Sept
2011 under RA No. 7305 or the Magna Carta of Public Health Workers.
The purpose of R.A. 7305 is promoted and improve the social and economic wellbeing
of the health workers, their living and working conditions and terms of employment;
develop their skills and capabilities in order that they will be more responsive and
better equipped to deliver health projects and programs; and, encourage those with
proper qualifications and excellent abilities to join and remain in government service.
Accordingly, public health workers (PHWs) were granted allowances and benefits, and
longevity pay. (5% ng monthy pay sa mga 5 years na nagwowork).
Doh Sec Alberto Romualdez issued a cert declaring PhilHealth officers and employees
as public health workers. Office of Government Corp Counsel gave a opinion stating
that the term health-related work under sec 3 f RA 7305 includes not only the direct
delivery or provision of health services but also the aspect of financing and regulating
of health services. The PhilHealth officers and employees were deemed engaged in
health-related works for purposes of entitlement to the longevity pay.
So PhilHealth prescribe guideline on the grant of longevity, passing and approving a
resolution for it. However, COA Supervising Auditor Elena Agustin found lack of legal
basis for th grant of longevity pay, she recommended the discontinuance of it.
PhilHealth argued that PhilHealth personnel were public health workers and opined by
the OGCC, it is therefore, entitled to the grant. However Auditor Augustin is still
unsatisfied for the grant. Therefore, PhilHealth filed an appeal memorandum for COA
Government Sector but they were denied. For PhilHealth personnel were not public
health workers but merely engages in paying and utilization og health services by its
covered beneficiaries. When they again tried to file a petition for review, it was
dismissed for being filed out of time and under Sec 48 of PD 1445 the reglementary
period to appeal the decision of an auditor is 6 months only.
Therefore, in this case, PhilHealth questions the jurisdiction of COA
ISSUE
Did COA gravely abused its discretion amounting to lack or excess of jurisdiction?
RULING
No. An aggrieved party can assail the Decision of the COA through a petition for
certiorari under Rule 64, as ruled in the case of Maritime Industry Authority v.
Commission on Audit, 745 SCRA 300 (2015):
A petition under Rule 64 may prosper only after a finding that the administrative
agency committed grave abuse of discretion amounting to lack or excess of jurisdiction.
Not all errors of the Commission on Audit are reviewable by this court. Thus, a Rule 65
petition is a unique and special rule because it commands limited review of the
question raised. As an extraordinary remedy, its purpose is simply to keep the public
respondent within the bounds of its jurisdiction or to relieve the petitioner from the
public respondent’s arbitrary acts. In this review, the Court is confined solely to
questions of jurisdiction whenever a tribunal, board or officer exercising judicial or
quasi-judicial function acts without jurisdiction or in excess of jurisdiction, or with
grave abuse of discretion amounting to lack or excess of jurisdiction. The limitation of
the Court’s power of review over COA’s rulings merely complements its nature as an
independent constitutional body that is tasked to safeguard the proper use of the
government and, ultimately, the people’s property by vesting it with power to (i)
determine whether the government entities comply with the law and the rules in
disbursing public funds; and (ii) disallow legal disbursements of these funds.
This Court has consistently held that findings of administrative agencies are generally
accorded not only respect but also finality, unless found to have been tainted with grave
abuse of discretion.

MARIA THERESA BONOT Vs EUNICE PRILA

G.R. NO. 219525. AUGUST 6 2018
FACTS
This case is a petition for review on certiorari under Rule 45 of ROC assails the decision
and resolution of CA which reversed and set aside the decision of the CSC dismissing
the administrative complaint for grave misconduct filed by respondent Eunice Prila
against Maria Theresa Bonot.
Prila worked as Administrative Aide III at the Central Bicol State University of
Agriculture. While Dra Bonot is dean of the College of Arts and Science at CBSUA. Prila
was informed by her colleagues that Dra Bonot has been uttering defamatory
statements about her.
To support her charge, Prila submitted sworn preliminary inquiry stating that she was
sexually harassed by Dr Alden Bonot, the husband of petitioner. The CSCRO5 ordered
Dra Bonot to submit her counter-affidavit together with affidavit of her witnesses and
other documentary evidence. Dra. Bonot raised the defense that the accusatory
statements of Prila against her were not based on the personal knowledge of Prila and
were hearsay. All members of CBSUA averred that they had never heard Dra utter a
defamatory statement against anyone.
CSCRO decided dismissing the complain as there was no witness attested to the truth of
Prila. Prila then filed an Entry of Appearance with motion for reconsideration alleging
that the summary dismissal of her complaint was tantamount to deprivation of her
constitutional right to due process as she was denied the opportunity to substantiate
her charge by adducing additional evidence.
In arriving at its conclusion that the complaint of Prila should be dismissed for want of
merit, the CSC considered the statements of Prila and her witnesses vis-à-vis the
refutation of said statements by Dra. Bonot and her own witnesses, and found that the
evidence adduced by both parties were evenly balanced. In so ruling, the CSC applied
the equipoise doctrine, which provides that when the evidence for the prosecution and
defense are evenly balanced, the appreciation of such evidence calls for tilting of the
scales in favor of the accused. The complaint was still dismissed.
However, CA reversed the ruling remanding the case to the latter to allow Prila the
opportunity to substantiate her allegations in the complaint kasi that is violation of
constitutional right of Prila. And Dra Bonot oppose. CA said that there is no compelling
reason to modify or reverse the decision.
ISSUE
Is Prila derived from her constitutional right?
RULING
No. As can be gleaned from the assailed decision of the CA, the ratio decidendi in its
reversal of the CSC’s dismissal of the complaint lies in the supposed deprivation of
Prila’s fundamental right to due process. While We agree with the finding of the CA
that fair and reasonable opportunity must be given to both parties to explain their
respective sides of the controversy and present evidence in support thereof, the records
show that the CSC had already taken the supporting evidence submitted by Prila (i.e.,
the affidavits of Alanis and Rivero) into consideration when it rendered its Decision 22
dated April 8, 2013.