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JurisprudenceG.R. No. 250089 -

G.R. No. 250089 - PHILIPPINE HEALTH INSURANCE CORPORATION, VS. COMMISSION ON AUDIT AND CHAIRPERSON MICHAEL G. AGUINALDO.

En Banc

Cited Laws

RA 6686,RA 11223,RA 6758RA 8441,RA 11223RA 1,RA 7875,RA 7656RA 10606RA 6758,RA 7305,RA 7875RA 9241RA 7305
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Decision

Ruling

Accordingly, the indiscriminate grant of personnel benefits sans executive imprimatur necessitates the disallowance. After all, to sustain petitioner's claim that it alone would ensure that its compensation system would conform with applicable law will result in "an invalid delegation of legislative power, granting the PHIC [petitioner] unlimited authority to unilaterally fix its compensation structure. Certainly, such effect could not have been the intent of the legislature."' [46] As prescribed by the Court En Banc in Philhealth v. Commission on Audit : [47] Thus, it is settled that in granting any additional personnel benefits, PHIC is required to observe the policies and guidelines laid down by the OP relating to position classification, allowances, among other forms of compensation, and to report to the OP, through the DBM, on its position classification and compensation plans, policies, rates and other necessary details following the guidelines as may be determined by the OP. Moreover, since PHIC failed to present any law or DBM issuance authorizing the grant of the benefits in question, the resulting disbursement and receipt are illegal and therefore, must be disallowed. Parenthetically, neither can petitioner seek refuge in alleging that Section 16(n) of R.A. No. 7875 is an exception to R.A. No. 6758. A judicious reading of the law reveals that GOCCs are clearly within its coverage. Enacted in 1989, the goal of R.A. No. 6758 was "to provide equal pay for substantially equal work and to base differences in pay upon substantive differences in duties and responsibilities, and qualification requirements of the positions." [48] The system established by the law applies to "all positions, appointive or elective, on full or part-time basis, now existing or hereafter created in the government, including government-owned or controlled corporations and government financial institutions." [49] Section 4 of the law defines covered GOCCs rather broadly to encompass "all corporations and financial institutions owned or controlled by the National Government, whether such corporations and financial institutions perform governmental or proprietary functions." In spite of such comprehensive inclusion, this Court in Engr. Mendoza v. Commission on Audit [50] ( Mendoza ) recognized that certain laws were passed exempting certain government entities from the law. Such entities have been expressly allowed via creating legislation to craft independent compensation and position classification systems that apply to their respective offices, some of which are the Philippine Postal Corporation, the Trade and Investment Development Corporation of the Philippines, Landbank of the Philippines, Social Security System, and the Philippine Deposit Insurance Corporation. [51] Glaringly, no such law has been passed by Congress insofar as exempting petitioner from abiding by the provisions of R.A. No. 6758. On that score, if Congress had indeed intended to exempt petitioner f