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JurisprudenceG.R. No. 261280 -

G.R. No. 261280 -

En Banc
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Decision

Ruling

WHEREFORE , .... the Motion for Partial Reconsideration of [Cochingco], former Regional Director (RD), et al., all of the [NEDA RO XIII], represented by the incumbent RD, [Uy] , is hereby DENIED . Accordingly, [COA] Decision No. 2018-306 dated March 15, 2018, which approved COA [NGS] Cluster 2 Decision No. 2015-03 dated January 12, 2015, is AFFIRMED with MODIFICATION , in that the employees who received the benefits remain liable to refund the amount they received. [23] (Citations omitted and emphasis supplied) Aggrieved, Dela Calzada et al. challenge the Decision. They argue that the COA Proper committed grave abuse of discretion when it reversed its previous ruling, which had already attained finality, excluding them from liability. They emphasized that they were not parties to the officers' Motion for Partial Reconsideration, and their right to due process was violated. [24] In any case, petitioners invoke good faith [25] and claim that the CEMA that they received has valid and sufficient factual and legal bases. [26] The COA Proper, through the Office of the Solicitor General (OSG), [27] counters that the Motion for Partial Reconsideration prevented Decision No. 2018-306 from attaining finality since the issue on the validity of the ND is not severable from the issue on the liabilities. [28] Assuming that Decision No. 2018-306 had already attained finality, the OSG posits that the exceptions on immutability of judgments apply, i.e., existence of special or compelling circumstances. Specifically, the OSG argues that the application of the supervening jurisprudence and the correction of the inequitable effect of making the officers solely liable for the disallowed amount are sufficient justifications for the COA Proper to rectify its previous ruling on petitioners' liability. [29] Issue Whether the COA Proper committed grave abuse of discretion in reinstating the liability of Dela Calzada et al. in the ND based on the Motion for Partial Reconsideration filed by the approving and/or certifying officers. Ruling We answer in the affirmative. Generally , this Court sustains the rulings of the COA in deference to its constitutional mandate with regard to expenditures of government funds, as well as its presumed expertise in the laws entrusted to them to enforce. [30] However, through the extraordinary writ of certiorari , the Court would annul decisions and resolutions of the COA when it has clearly acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction." [31] We have consistently explained: The special civil action for certiorari is intended for correction of errors of jurisdiction ... or grave abuse of discretion amounting to lack or excess of jurisdiction. Its principal office is ... to keep the inferior court within the parameters of its jurisdiction or to prevent it from committing such a grave abuse of discretion amounting to lack or excess of jurisdiction. .... Excess of jur