G.R. No. 258100 - PHILIPPINE HEALTH INSURANCE CORPORATION, VS. COMMISSION ON AUDIT, AS REPRESENTED BY ITS CHAIRPERSON, MICHAEL G. AGUINALDO.D E C I S I O N - Supreme Court E-Library

Ruling

WHEREFORE, premises considered, the Petition for Review of Philippine Health Insurance Corporation (PhilHealth) Regional Office (RO) No. IV-A, represented by its Regional Vice President, Mr. Alberto C. Manduriao, is hereby DENIED for lack of merit. Accordingly, Commission on Audit RO No. IV-A Decision No. 2014-23 dated March 19, 2014, which affirmed Notice of Disallowance (ND) Nos. 11-001-GF (9), 11-002-GF (09), 11-003-GF (10), 11-004-GF (09), and 11-005-GF (10), all dated November 15, 2011, on the payment of Transportation Allowance, Educational Assistance Allowance, and Project Completion Incentive for calendar years 2009 and 2010, in the total amount of P15,287,405.63, is AFFIRMED. The Supervising Auditor and the Audit Team Leader shall issue a Supplemental ND to the members of PhilHealth Board of Directors who authorized the grant of Transportation Allowance, Educational Assistance Allowance, and Project Completion Incentive. [21] The COA Commission Proper ruled that Section 16(n) of RA 7875 is a general statement of powers and functions of the PHIC BOD that cannot be equated to fiscal autonomy or absolute power in fixing the compensation and benefits of its personnel. As such, PHIC is duty-bound to observe the guidelines and policies under Section 12 of RA 6758, Section 6 of Presidential Decree No. (PD) 1597, and Section 9 of Congress Joint Resolution No. (JR) 04 dated 17 June 2009, consistent with the ruling in Philippine Health Insurance Corporation v. Commission on Audit [22] (2016 PHIC case) . It rejected the argument that former Pres. Macapagal-Arroyo confirmed the fiscal autonomy of PHIC and found no basis in the claim that the exclusive authority of the BOD to approve PHIC's internal operating budget comes from the fact that it does not require budgetary support from the national government. Accordingly, the COA Commission Proper affirmed the subject NDs and found the approving, authorizing, and certifying officers for the disallowed benefits, as well as the PHIC BOD, solidarily liable therefor. It ratiocinated that the concerned BOD and officers had knowledge of the irregularity of the benefits because disallowances of the same nature had been previously issued. Upon motion for reconsideration, [23] the COA Commission Proper modified the assailed decision in Decision No. 2020-466 dated 31 January 2020, excusing two officers from solidary liability since neither were approving nor authorizing officers for the disbursement of funds while remaining liable for the amounts they received. The fallo reads: WHEREFORE, premises considered, the Motion for Reconsideration of Philippine Health Insurance Corporation Regional Office No. IV-A, Lucena City, represented by Dr. Elizabeth S. Fernandez, Regional Vice President, is hereby DENIED. Accordingly, Notice of Disallowance (ND) Nos. 11-001-GF (09), 11-002-GF (09), 11-003-GF (10), 11-004-GF (09), and 11-005-GF (10), all dated November 15, 2011, on the payment of Transportation Allowance, Educatio