G.R. Nos. 145383-84 - ATTY. RUDY M. VILLAREÑA, VS. THE COMMISSION ON AUDIT.D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, in case of a conflict between Republic Act No. 6758 and the Local Government Code, the proper action is not to uphold one and annul the other, but, if possible, to give effect to both by harmonizing the two. In Magtajas v. Pryce , [10] a conflict arose between the Local Government Code and Presidential Decree No. 1869, the charter of PAGCOR. In that case, the Sanggunian Panlungsod of Cagayan de Oro passed an ordinance revoking the business permits of establishments engaged in casino operations in its jurisdiction. It claimed that although PAGCOR is empowered by its charter to establish and operate casinos, local councils are permitted by the Local Government Code to prohibit all forms of gambling within their territories. Its main argument was that the Local Government Code, which is a later enactment, had the effect of modifying the charter of PAGCOR. The Court, instead of annulling one law and upholding the other, harmonized both laws by declaring Presidential Decree No. 1869 as an exception to the Local Government Code. In the case at bar, the two statutes can easily be harmonized. Under the Local Government Code, local legislative bodies may provide for additional allowances and other benefits to national government officials stationed or assigned to their municipality or city. This authority, however, is not without limitation, as it does not include the grant of benefits that runs in conflict with other statutes, such as Republic Act No. 6758. The exception stated in these laws must be read together with the Local Government Code, so as to make both the Code and these laws equally effective and mutually complementary. By allocating a portion of the local budget for financial assistance to the auditing office of Marikina City, the legislative council of Marikina acted in excess of its powers under the Local Government Code. Consequently, Ordinance No. 21, series of 1995; Ordinance No. 9, series of 1996; and Ordinance No. 200, series of 1996, insofar as these contravene the prohibition contained in Republic Act No. 6758, are declared invalid. Petitioner next argues that Section 18 of Republic Act No. 6758 violates the equal protection clause of the Constitution. Petitioner ignores the well-accepted meaning of the equal protection clause. This clause does not preclude classification of individuals who may be accorded different treatment under the law as long as the classification is reasonable and not arbitrary. [11] Indeed, there are valid reasons to treat COA officials differently from other national government officials. The primary function of an auditor is to prevent irregular, unnecessary, excessive or extravagant expenditures of government funds. [12] To be able properly to perform their constitutional mandate, COA officials need to be insulated from unwarranted influences, so that they can act with independence and integrity. As extensively discussed in Tejada v. Domingo , [13] the prohibition under Section 18 of Republic