G.R. No. 258424 - PHILIPPINE HEALTH INSURANCE CORPORATION, VS. COMMISSION ON AUDIT, REPRESENTED BY ITS CHAIRPERSON, MICHAEL G. AGUINALDO.

Ruling

WHEREFORE , premises considered, the Petition for Review of the employees of the Philippine Health Insurance Corporation (PhilHealth) Regional Office (RO) No. VI, is PARTIALLY GRANTED . Accordingly, Commission on Audit Corporate Government Sector-Cluster 6 Decision No. 2014-016 dated November 14, 2014, sustaining Notice of Disallowance (ND) Nos. 12-030-100-(11) and 12-032-100[-](11), both dated July 13, 2012; 12-048-100[-11)] to 12-051-100[-(11)], all dated December 10, 2012; and 2013-001-100(12) to 2013-007-100(12), all dated January 10, 2013, on the payment of various allowances and benefits in the total amount [PHP] 5,010,607.83, is hereby AFFIRMED with MODIFICATION , in that the payees need not refund the disallowed benefits they received. However, the approving and certifying officers, shall remain solidarily liable for the disallowance, in total amount of [PHP]5,010,607.83. [11] A motion for reconsideration [12] was filed, where the PhilHealth Regional Office VI employees additionally asserted that the officers should likewise be absolved from refunding the amounts received [13] and that at any rate, the allowances and benefits were compliant with the law. [14] In its Resolution, the COA held that the arguments on the motion for reconsideration are mere rehash of arguments already raised before it and were already discussed in the Decision. [15] Further, the COA held that good faith cannot be a defense as the PhilHealth employees cannot feign ignorance of the laws and rules requiring prior approval from the president and the DBM. [16] The presumption of regularity in the performance of duties could not also be appreciated, as there is an explicit rule that was violated. [17] As to the payees, they were required to return the amounts they received, citing the case of Madera v. Commission on Audit [18] ( Madera ) and the principles of solutio indebiti and unjust enrichment. [19] Thus, in the Resolution, the COA denied the motion for reconsideration and ordered the recipients to refund the amounts they received, in addition to the approving and certifying officers being solidarily liable for the same, thus: WHEREFORE , premises considered, the Motion for Reconsideration of Philippine Health Insurance Corporation Regional Office No. VI, of Commission on Audit (COA) Decision No. 2019-264 dated June 25, 2019, is hereby DENIED . Accordingly, Notice of Disallowance Nos. 12-030-100-(11) and 12-032-100[-](11), both dated July 13, 2012; 12-048-100[-(11)] to 12-051-100[-(11)], all dated December 10, 2012; and 2013-001-100(12) to 2013-007-100(12), all dated January 10, 2013 are hereby AFFIRMED and COA Decision No. 2019-264 dated June 25, 2019, is hereby MODIFIED , in that all the officials named liable therein shall be solidarily liable for the amounts corresponding to what they approved and certified, including the amount they received which they shall refund as payees. The recipient-employees are liable to the extent of the amount that they received.