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RODOLFO S. DE JESUS v. COA

This case has been cited 11 times or more.

2015-02-10
BERSAMIN, J.
The Court agrees with the COA decision in holding that the recipients of the healthcare maintenance allowance benefits who received the allowance of P5,000.00 in good faith need not refund the sum received. The recipients accepted the benefits honestly believing that they were receiving what they were entitled to under the law. Similarly, the Court holds that the TESDA officials who granted the allowance to the covered personnel acted in good faith in the honest belief that there was lawful basis for such grant. In view of these considerations, the Court declares that the disallowed benefits approved and received in good faith need not be reimbursed to the Government. This finds support in the consistent pronouncements of the Court, such as that issued in De Jesus v. Commission on Audit,[21] to wit:Nevertheless, our pronouncement in Blaquera v. Alcala supports petitioners' position on the refund of the benefits they received. In Blaquera, the officials and employees of several government departments and agencies were paid incentive benefits which the COA disallowed on the ground that Administrative Order No. 29 dated 19 January 1993 prohibited payment of these benefits. While the Court sustained the COA on the disallowance, it nevertheless declared that:
2014-03-11
CARPIO, J.
On 4 July 2008, TESDA, through its then Director-General Augusto Boboy Syjuco, Jr., filed an Appeal Memorandum[7] arguing that the 2004-2007 GAAs and the Government Accounting and Auditing Manual allowed the grant of EME from both the General Fund and the TESDP Fund provided the legal ceiling was not exceeded for each fund. According to TESDA, the General Fund and the TESDP Fund are distinct from each other, and TESDA officials who were designated as project officers concurrently with their regular functions were entitled to separate EME from both funds.
2009-09-25
DEL CASTILLO, J.
This ruling has been consistently applied in several cases.[37]
2006-02-16
AZCUNA, J.
In regard to the refund of  the disallowed benefits, this Court  holds that petitioners  need not refund the benefits received by them based on our rulings in Blaquera v. Alcala,[7] De Jesus v. Commission on Audit[8] and Kapisanan ng mga Manggagawa sa Government Service Insurance System (KMG) v. Commission on Audit.[9] 
2005-08-25
SANDOVAL-GUTIERREZ, J.
In Querubin vs. Regional Cluster Director, Legal and Adjudication Office, COA Regional Office VI, Pavia, Iloilo City,[10] citing De Jesus vs. Commission on Audit,[11] this Court held:"Considering, however, that all the parties here acted in good faith, we cannot countenance the refund of subject incentive benefits for the year 1992, which amounts the petitioners have already received. Indeed, no indicia of bad faith can be detected under the attendant facts and circumstances. The officials and chiefs of offices concerned disbursed such incentive benefits in the honest belief that the amounts given were due to the recipients and the latter accept the same with gratitude, confident that they richly deserve such benefits.
2004-08-31
TINGA, J,
The COA, on the other hand, is vested by the Constitution with the power and duty to examine, audit and settle all accounts pertaining to the revenue and receipts of, and expenditures or uses of funds or property owned or held in trust by, or pertaining to government owned and controlled corporations with original charters such as the GSIS, on a post-audit basis.[50] It is mandated to determine whether government entities comply with laws and regulations in disbursing government funds, and to disallow illegal or irregular disbursements of government funds.[51]
2004-08-31
TINGA, J,
The Court however finds that the DOH and GSIS officials concerned who granted hazard pay under R.A. No. 7305 to the SIG personnel acted in good faith, in the honest belief that there was legal basis for such grant. The SIG personnel in turn accepted the hazard pay benefits likewise believing that they were entitled to such benefit. At that time, neither the concerned DOH and GSIS officials nor the SIG personnel knew that the grant of hazard pay to the latter is not sanctioned by law. Thus, following the rulings of the Court in De Jesus v. Commission on Audit,[55] and Blaquera v. Alcala,[56] the SIG personnel who previously received hazard pay under R.A. No. 7305 need not refund such benefits.
2004-07-07
YNARES-SANTIAGO, J.
These queries have already been settled in the case of De Jesus v. Commission on Audit.[7] Applying Baybay Water District v. Commission on Audit,[8] it was held in De Jesus that Section 13 of PD 198, as amended,[9] categorically forbids the grant of bonuses and allowances other than payment of per diems. De Jesus likewise declared that LWUA Resolution No. 313, series of 1995, which grants compensation and other benefits to the members of the Board of Directors of Local Water Districts, is not in conformity with Section 13 of PD 198, as amended.  Nevertheless, it was held therein that the disallowed monetary benefits received by the Board Members concerned in 1997 and 1998 need not be refunded by the recipient Board Members because they received the same before Baybay Water District was promulgated on January 23, 2002.  They were therefore of the honest belief that LWUA Board Resolution No. 313 was valid, thus This issue was already resolved in the similar case of Baybay Water District v. Commission on Audit. In Baybay Water District, the members of the board of Baybay Water District also questioned the disallowance by the COA of payment of RATA, rice allowance and excessive per diems. The Court ruled that PD 198 governs the compensation of members of the board of water districts. Thus, members of the board of water districts cannot receive allowances and benefits more than those allowed by PD 198. Construing Section 13 of PD 198, the Court declared: x x x     Under S[ection] 13 of this Decree, per diem is precisely intended to be the compensation of members of board of directors of water districts. Indeed, words and phrases in a statute must be given their natural, ordinary, and commonly-accepted meaning, due regard being given to the context in which the words and phrases are used. By specifying the compensation which a director is entitled to receive and by limiting the amount he/she is allowed to receive in a month, and, in the same paragraph, providing "No director shall receive other compensation" than the amount provided for per diems, the law quite clearly indicates that directors of water districts are authorized to receive only the per diem authorized by law and no other compensation or allowance in whatever form. Section 13 of PD 198 is clear enough that it needs no interpretation. It expressly prohibits the grant of compensation other than the payment of per diems, thus preempting the exercise of any discretion by water districts in paying other allowances and bonuses.                         x x x                             x x x                             x x x Nevertheless, our pronouncement in Blaquera v. Alcala supports petitioners' position on the refund of the benefits they received. In Blaquera, the officials and employees of several government departments and agencies were paid incentive benefits which the COA disallowed on the ground that Administrative Order No. 29 dated 19 January 1993 prohibited payment of these benefits. While the Court sustained the COA on the disallowance, it nevertheless declared that: Considering, however, that all the parties here acted in good faith, we cannot countenance the refund of subject incentive benefits for the year 1992, which amounts the petitioners have already received. Indeed, no indicia of bad faith can be detected under the attendant facts and circumstances. The officials and chiefs of offices concerned disbursed such incentive benefits in the honest belief that the amounts given were due to the recipients and the latter accepted the same with gratitude, confident that they richly deserve such benefits. This ruling in Blaquera applies to the instant case. Petitioners here received the additional allowances and bonuses in good faith under the honest belief that LWUA Board Resolution No. 313 authorized such payment. At the time petitioners received the additional allowances and bonuses, the Court had not yet decided Baybay Water District. Petitioners had no knowledge that such payment was without legal basis. Thus, being in good faith, petitioners need not refund the allowances and bonuses they received but disallowed by the COA. Accordingly, the Court sustains the disallowance of the monetary benefits granted to petitioners Members of the Board of the BCWD in accordance with LWUA Resolution No. 313, series of 1995.  Having been granted said allowances and bonuses in 1999, before the Court declared in Baybay Water District the illegality of payment of additional compensation other than the allowed per diem in Section 13, of PD 198, as amended, they can thus be considered to have received the same in good faith.  Hence, they need not refund them.
2004-02-05
YNARES-SATIAGO, J.
The issues posed in the instant petition had been settled in De Jesus v. Commission on Audit,[7] where the Court affirmed the COA's disallowance of a similar grant of bonuses and allowances under LWUA Resolution No. 313, series of 1995.
2004-01-14
CARPIO, J.
Petitioner seeks to revive a well-settled issue.  Petitioner asks for a re-examination of a doctrine backed by a long line of cases culminating in Davao City Water District v. Civil Service Commission[5] and just recently reiterated in De Jesus v. Commission on Audit.[6] Petitioner maintains that LWDs are not government-owned and controlled corporations with original charters.  Petitioner even argues that LWDs are private corporations.  Petitioner asks the Court to consider certain interpretations of the applicable laws, which would give a "new perspective to the issue of the true character of water districts."[7]
2003-11-19
YNARES-SANTIAGO, J.
Notwithstanding the validity of the disallowance by the COA, however, the officers and employees of PITC can not be obliged to refund the SFI received by them in good faith. In the recent case of De Jesus v. Commission on Audit,[23] it was held that the Members of the Board of the Catbalogan Water District cannot be ordered to refund the bonuses received by them because they were of the honest belief that they were authorized to approve and receive said payment. At the time they received the said benefits, the case of Baybay Water District v. Commission on Audit,[24] which categorically denied the grant of additional compensation to the Members of the Board of water districts, was not yet decided. It was held that the language of Section 13 of P.D. No. 198, (the Provincial Water District Act of 1973, as amended) is clear enough that it needs no interpretation. Local Water District Utilities Administration Resolution No. 131, series of 1995, cannot justify the disbursement of additional allowances because Section 13 of P.D. No. 198, expressly prohibits the members of the board of water districts from receiving compensation other than payment of per diem.