SOCIAL SECURITY SYSTEM, VS. COMMISSION ON AUDIT.

Ruling

WHEREFORE , premises considered, Commission on Audit Cordillera Administrative Region Decision No. 2016-014[,] dated April 5, 2016, which denied the appeals of Social Security System (SSS), on the grant of Collective Negotiation Agreement incentives to the rank-and-file employee of SSS-North Luzon Cluster for calendar years 2005 to 2008, and reduced the amount of disallowance, is hereby APPROVED . Accordingly, Notice of Disallowance (ND) Nos. 2012-001-(2008) dated[,] April 13, 2002, and 2012-002-(2010)[,] dated April 17, 2012[,] in the amounts of [PHP] 3,626,505.53 and [PHP] 16,612,484.21, respectively, are hereby AFFIRMED ,while ND No. 2012-003-(2005-2008) dated April 17, 2012 is AFFIRMED with MODIFICATION ,in that the amount of disallowance is reduced from [PHP] 464,264.34 to [PHP] 459,981.36. The Supervising Auditor and the Audit Team Leader are hereby directed to evaluate the participation of the members of the Social Security Commission in the issuance of the various resolutions on the grant of the CNA incentives and issue a supplemental ND against them, if warranted. (Emphasis in the original). 40 Hence, the SSS filed this Petition before the Court seeking to set aside the COA CP Decision, annul the assailed NDs, and declare the recipients as well as the certifying and approving officers as free from liability to refund the disallowed amounts. To support its Petition, the SSS reiterated the arguments it raised before the COA. The Issue Did COA commit grave abuse of discretion when it affirmed the assailed NDs? The Ruling of the Court The Petition must fail. At the outset, it must be emphasized that Rule 64 petitions assailing COA decisions are limited to a review by this Court of jurisdictional errors or claims of grave abuse of discretion. 41 This regard by the Court for the decisions of administrative authorities, especially those which are constitutionally created, such as the COA, is underpinned by the doctrine of separation of powers, as well as the recognition of the presumed expertise in the laws these administrative bodies are entrusted to enforce. 42 The Court explained in Madera v. COA 43 that grave abuse of discretion exists when the assailed decision or resolution is not based on law and the evidence, but on caprice, whim, and despotism, thus: The Constitution vests the broadest latitude in the COA in discharging its role as the guardian of public funds and properties. In recognition of such constitutional empowerment, the Court has generally sustained the COA's decisions or resolutions in deference to its expertise in the implementation of the laws it has been entrusted to enforce. Thus, the Constitution and the Rules of Court provide the remedy of a petition for certiorari in order to restrict the scope of inquiry to errors of jurisdiction or to grave abuse of discretion amounting to lack or excess of jurisdiction committed by the COA. For this purpose, grave abuse of discretion means that there is, on the part of the