Administrative Law

Case Digest
Activity 3

1. G.R. No. 162059 January 22, 2008

HANNAH EUNICE D. SERANA, petitioner, vs.
SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, respondents.

FACTS:
The petitioner, Hannah Eunice D. Serana, was a senior student at the University of the
Philippines-Cebu and was appointed as a student regent of UP by then President
Joseph Estrada.
Petitioner, along with her siblings and relatives, registered the Office of the Student
Regent Foundation, Inc. (OSRFI).
OSRFI received Fifteen Million Pesos (P15,000,000.00) from President Estrada for the
renovation of Vinzons Hall Annex, with the source of funds noted as the Office of the
President.
ISSUE:
The main issue in this case is whether the Sandiganbayan has jurisdiction to try a
government scholar accused of swindling government funds.

RULING:
Jurisdiction over Estafa: The petitioner argued that the Sandiganbayan had no
jurisdiction over estafa. The court clarified that Sandiganbayan has jurisdiction over
cases involving public officers with Salary Grade 27 and above, and the offense
charged need not be specifically estafa. In this case, the Sandiganbayan had
jurisdiction because the petitioner held a government position.
Public Officer Status and Tuition Fees: The petitioner claimed she was not a public
officer with Salary Grade 27 and that she paid her tuition fees. The court ruled that her
position as a student regent constituted a public office for jurisdictional purposes,
regardless of tuition payments.
Relation to Office: The petitioner argued that the offense charged was not committed in
relation to her office. The court disagreed, stating that the alleged swindling involved
government funds intended for a project associated with her position as student regent.
Source of Funds: The petitioner claimed that the funds came directly from President
Estrada, not from the government. The court held that the source of funds didn't affect
jurisdiction; the crucial factor was whether the funds were for a project related to her
public office.

Additionally, the court admonished the petitioner's counsel for inaccuracies in citations
and emphasized the importance of candor and fairness in a lawyer's conduct before the
court.

RATIONALE:
The petition was denied for lack of merit, affirming the jurisdiction of the Sandiganbayan
to try the petitioner for swindling government funds related to her role as a student
regent. The court's rulings were based on the interpretation and application of Republic
Act No. 7975, which defines the jurisdiction of the Sandiganbayan and its applicability to
cases involving public officers and related offenses. The court consistently emphasized
that the nature of the position held and the connection to the office were pivotal in
determining jurisdiction, regardless of specific conditions or the source of funds.

2. G.R. No. 242342, March 10, 2020

National Power Corporation Board of Directors v. Commission on Audit

FACTS:
The National Power Corporation (NPC) Board of Directors authorized the payment of
the Employee Health and Wellness Program and Related Financial Assistance
(EHWPRFA) to NPC officials and employees. EHWPRFA amounted to P5,000.00 per
month, disbursed quarterly. However, the Commission on Audit (COA) disallowed the
payment for the first quarter of 2010, amounting to P29,715,000.00, as it was
considered a new benefit that lacked prior approval from the Office of the President, as
mandated by Memorandum Order No. 20. The COA affirmed this disallowance in its
decisions.

ISSUE:
Whether the COA committed grave abuse of discretion in ruling that EHWPRFA was a
new benefit.
Whether the COA committed grave abuse of discretion in ruling that the grant of
EHWPRFA needed presidential approval.

RULING:
The petitioners contended that EHWPRFA was not a new benefit but rather an
expansion of existing wellness benefits for NPC personnel, emphasizing that the
increase was necessary due to rising medicine prices. They argued that the President's
approval was effectively secured through the National Power Board, which includes the
DBM Secretary.

The COA maintained that EHWPRFA was indeed a new benefit, subject to the Salary
Standardization Law and presidential approval. Memorandum Order No. 20 explicitly
required presidential approval for increases in compensation for government-owned or -
controlled corporations (GOCCs). The COA disagreed that the National Power Board's
composition exempted EHWPRFA from presidential approval, as cabinet members
serving on the board could not extend the alter ego doctrine to their ex officio acts.

The Court upheld the COA's findings, emphasizing that the COA, as the guardian of
public funds, had the authority to disallow irregular or excessive expenditures. The
COA's decisions were considered final unless it had acted without jurisdiction, in excess
of jurisdiction, or with grave abuse of discretion.

The Court found no grave abuse of discretion on the COA's part and affirmed its
decisions. Consequently, the certifying and approving officers and the employees who
received the disallowed benefit were held liable for reimbursement, with the mode of
payment determined by the COA.

RATIONALE:
In this case, the COA's decision to disallow the EHWPRFA payment for the first quarter
of 2010 was upheld. The COA had not acted with grave abuse of discretion, and the
petitioners were ordered to reimburse the disallowed amount as determined by the
COA.
 3. Philippine Institute for Development Studies v. COA (G. R. No. 212022, August
20, 2019)

FACTS:
President Ferdinand E. Marcos issued Presidential Decree No. 1597, allowing
government employees to receive allowances, honoraria, and fringe benefits with
presidential approval.
President Fidel V. Ramos issued Administrative Order No. 402, enabling government
agencies to establish an annual medical checkup program.
The Philippine Institute for Development Studies (PIDS) sought authorization to
establish a health maintenance program instead of the annual medical checkup under
Administrative Order No. 402.
PIDS was advised to seek exemption from the Office of the President, which it did.
PIDS entered a Health Care Agreement with PhilamCare Health System, Inc. to provide
healthcare services to its employees.

ISSUE:
The main issue is whether the Commission on Audit (COA) erred in upholding the
validity of Notice of Disallowance No. 11-001-(6-10).

RULING:
The court ruled in favor of PIDS, concluding that COA erred in its decision. The court
stated that the approval for exemption from the Office of the President did not exempt
PIDS from Administrative Order No. 402. The Senior Deputy Executive Secretary
lacked authority to exempt an agency from an administrative order.

The court emphasized that procuring health insurance from private companies does not
constitute the disbursement of public funds, which was the concern of COA Resolution
No. 2005-001. The annual medical checkup program implemented by PIDS was
considered an alternative to the government's healthcare program through PhilHealth,
not an additional insurance.
Therefore, the agreements made by PIDS did not violate Commission on Audit
Resolution 2005-001. The court granted the petition and reversed the COA decision,
setting aside the Notice of Disallowance No. 11-001-(06-10).

RATIONALE:
The case is rooted in the delineation of presidential authority under Presidential Decree
No. 1597 and the enforceability of administrative orders, exemplified by Administrative
Order No. 402. It elucidates that only the President or duly authorized officials possess
the prerogative to grant exemptions from administrative orders, a power that Senior
Deputy Executive Secretaries do not inherently wield. Crucially, the case underscores
that procuring health insurance from private entities does not inherently entail the use of
public funds, aligning with the intent of COA Resolution No. 2005-001 to safeguard
against improper fund disbursement. Furthermore, it discerns between an alternative
healthcare program and an additional allowance, concluding that the Philippine Institute
for Development Studies' program falls into the former category and thus does not
transgress the regulations governing additional allowances, resulting in the reversal of
the COA's decision.

4. G.R. No. 81563 (December 19, 1989)

FACTS:
This case revolves around the conviction of six accused individuals, including Amado C.
Arias and Cresencio D. Data, in connection with the overpricing of land purchased by
the Bureau of Public Works for the Mangahan Floodway Project. The project aimed to
mitigate floods in Marikina and Pasig, Metro Manila. The accused were charged with
causing undue injury to the government and providing unwarranted benefits to a private
party through manifest partiality, evident bad faith, or inexcusable negligence.
Specifically, they were accused of selling "riceland" in Rosario, Pasig, assessed at
P5.00 per square meter in 1973, as residential land in 1978 for P80.00 per square
meter.

ISSUE:
The primary issue in this case is whether Amado C. Arias and Cresencio D. Data should
be convicted of conspiring to cause undue injury to the government through the irregular
disbursement and expenditure of public funds.
RULING:
The majority opinion of the court led to the acquittal of petitioners Arias and Data on the
grounds of reasonable doubt. The Court believed that the evidence presented did not
meet the standard required to convict them beyond a reasonable doubt.
The Court concurred with the Solicitor-General's recommendation that the petitioners be
acquitted. The records showed that the assessor's tax valuation of P5.00 per square
meter for the land in question was unrealistic and arbitrary as a basis for conviction. The
Court emphasized that the petitioners were not charged with conspiracy in the
falsification of public documents but with causing undue injury to the government.
The alleged undue injury was based on the government's purchase of land at P80.00
per square meter instead of the P5.00 value per square meter stated in tax declarations.
The Court found that the Sandiganbayan had wrongly assumed that the P5.00 per
square meter value fixed by the assessor was the correct market value, leading to the
conclusion of undue injury. The Court argued that this assumption was flawed.
The principal error of the respondent court, according to the Court, was setting a
precedent where a head of office could be convicted in a conspiracy simply because
they did not personally examine every detail of a transaction. The Court believed that
the evidence did not adequately establish the guilt of the petitioners beyond a
reasonable doubt.

RATIONALE:
In conclusion, the Court set aside the Sandiganbayan’s decision convicting and
sentencing Amado C. Arias and Cresencio D. Data. The petitioners were acquitted on
the grounds of reasonable doubt, with no costs imposed.
The case involved the acquittal of Amado C. Arias and Cresencio D. Data, who were
charged with conspiring to cause undue injury to the government through the irregular
disbursement of public funds in the purchase of land for a flood mitigation project. The
Court ruled in their favor, citing the lack of sufficient evidence to convict them beyond a
reasonable doubt and emphasizing that they were not charged with falsifying public
documents. The Court also criticized the assumption that the tax valuation was the
correct market value and the precedent it could set for officials held responsible for the
actions of subordinates.
References:
G.R. No. 162059. (n.d.).
https://lawphil.net/judjuris/juri2008/jan2008/gr_162059_2008.html
G.R. No. 242342. (n.d.).
https://lawphil.net/judjuris/juri2020/mar2020/gr_242342_2020.html
G.R. No. 212022. (n.d.). https://lawyerly.ph/digest/c1004c?
user=6994___________
G.R. No. 81563. (n.d.).
https://lawphil.net/judjuris/juri1989/dec1989/gr_81563_1989.html