GR 104217; (December, 1994) (Digest)
G.R. No. 104217 December 5, 1994
MANILA INTERNATIONAL AIRPORT AUTHORITY, petitioner, vs. COMMISSION ON AUDIT, respondent.
FACTS
The Manila International Airport Authority (MIAA), a government-owned and controlled corporation, granted its Department and Division Managers Representation and Transportation Allowance (RATA) equivalent to 40% of their basic salary, pursuant to Letter of Implementation (LOI) No. 97. Following the effectivity of Republic Act No. 6758 , the Compensation and Position Classification Act of 1989, on July 1, 1989, MIAA adjusted these RATA payments to 40% of the new standardized salary rates for the period July 1989 to June 1990. The MIAA Resident Auditor disallowed the resulting increase, amounting to P1,215,947.96, asserting that the grant violated R.A. No. 6758 and related circulars. The auditor contended that payments after June 30, 1989, should be based on the highest RATA amount actually received as of that date, not on a percentage of the new standardized salary. The Commission on Audit affirmed the disallowance, prompting MIAA and the affected officials to file this petition for certiorari.
ISSUE
The primary issue is whether the RATA granted under LOI No. 97, specifically at 40% of basic salary, was repealed or amended by R.A. No. 6758 , and consequently, whether the post-July 1, 1989, RATA should be based on the pre-standardization amount received as of June 30, 1989, or on 40% of the new standardized salary.
RULING
The Supreme Court granted the petition and set aside the COA disallowance. The Court ruled that LOI No. 97 was not entirely repealed but was amended by R.A. No. 6758 only to the extent of limiting the continued grant of RATA to incumbents as of July 1, 1989, in line with the policy of non-diminution of pay. Crucially, the Court rejected the COA’s interpretation that July 1, 1989, served as a cut-off date fixing the RATA amount forever based on the pre-standardization rate. Citing its precedent in Philippine Ports Authority v. Commission on Audit, the Court held that the date July 1, 1989, is significant only for determining the incumbent status of an official entitled to continue receiving RATA; it does not freeze the RATA amount. Therefore, the RATA should be computed based on the authorized rate under LOI No. 97—40%—applied to the new standardized salary prescribed by R.A. No. 6758 . The adjustment made by MIAA was valid.