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PHILIPPINE ECONOMIC ZONE AUTHORITY v. COA

This case has been cited 2 times or more.

2015-01-13
LEONEN, J.
In Philippine Economic Zone Authority v. Commission on Audit,[134] this court defined good faith relative to the requirement of refund of disallowed benefits or allowances.
2014-03-11
CARPIO, J.
In Blaquera v. Alcala,[28] the Court no longer required the officials and employees of different government departments and agencies to refund the productivity incentive bonus they received because there was no indicia of bad faith and the disbursement was made in the honest belief that the recipients deserved the amounts. We, however, qualified this Blaquera ruling in Casal v. COA,[29] where we held the approving officials liable for theĀ  refund of the incentive award due to their patent disregard of the issuances of the President and the directives of COA. In Casal, we ruled that the officials' failure to observe the issuances amounted to gross negligence, which is inconsistent with the presumption of good faith. We applied the Casal ruling in Velasco v. COA,[30] to wit: x x x the blatant failure of the petitioners-approving officers to abide with the provisions of AO 103 and AO 161 overcame the presumption of good faith. The deliberate disregard of these issuances is equivalent to gross negligence amounting to bad faith. Therefore, the petitioners-approving officers are accountable for the refund of the subject incentives which they received.