G.R. No. 213453 - PHILIPPINE HEALTH INSURANCE CORPORATION, VS. COMMISSION ON AUDIT, MA. GRACIA PULIDO TAN, CHAIRPERSON; AND JANET D. NACION, DIRECTOR IV.D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, when respondent disallowed petitioner's grant of certain allowances in its exercise of said power, it effectively and directly challenged petitioner's authority to grant the same. Thus, petitioner must be granted the opportunity to justify its issuances by presenting the basis on which they were made. As petitioner pointed out, whatever benefit received by the personnel as a consequence of PHIC's exercise of its alleged authority is merely incidental to the main issue, which is the validity of PHIC's grant of allowances and benefits. [38] In fact, in light of numerous disallowances being made by the COA, it is rather typical for a government entity to come before the Court and challenge the COA's decision invalidating such entity's disbursement of funds. [39] The non­participation of the particular employees who actually received the disallowed benefits does not prevent the Court from determining the issue of whether the COA gravely abused its discretion in declaring the entity's issuance as illegal. In Maritime Industry Authority v. COA , [40] We explained: The burden of proving the validity or legality of the grant of allowance or benefits is with the government agency or entity granting the allowance or benefit, or the employee claiming the same. After the Resident Auditor issues a notice of disallowance, the aggrieved party may appeal the disallowance to the Director within six (6) months from receipt of the decision. At this point, the government agency or employee has the chance to prove the validity of the grant of allowance or benefit. If the appeal is denied, a petition for review may be filed before the Commission on Audit Commission Proper. Finally, the aggrieved party may file a petition for certiorari before this court to assail the decision of the Commission on Audit Commission Proper. Our laws and procedure have provided the aggrieved party several chances to prove the validity of the grant of the allowance or benefit. [41] As Article IX-A, Section 7 of the 1987 Constitution expressly provides, "unless otherwise provided by this Constitution or by law, any decision, order, or ruling of each Commission may be brought to the Supreme Court on certiorari by the aggrieved party within thirty days from receipt of a copy thereof." In like manner, Rule 64, Section 2 of the Revised Rules of Civil Procedure also provides that "a judgment or final order or resolution of the Commission on Elections and the Commission on Audit may be brought by the aggrieved party to the Supreme Court on certiorari under Rule 65, except as hereinafter provided." Thus, while findings of administrative agencies, such as the COA herein, are generally respected, when it is shown to have been tainted with unfairness amounting to grave abuse of discretion, the aggrieved party can assail the COA decision in special civil action for certiorari under Rule 64 in relation to Rule 65, an extraordinary remedy, the purpose of which is to keep the public responde