GR 128134; (October, 2000) (Digest)
G.R. No. 128134; October 18, 2000
FE D. LAYSA, in her capacity as Regional Director of the Department of Agriculture, Regional Field Unit No. 5, petitioner, vs. COMMISSION ON AUDIT as represented by its Commissioner-Chairman, CELSO D. GANGAN, respondent.
FACTS
The Commission on Audit (COA) conducted a special audit on the Fishery Sector Program Fund of the Department of Agriculture Regional Office No. V for 1991-1992. The audit report revealed several irregularities, including procurement of equipment and services without public bidding and proper contracts, disbursements not founded on valid claims, purchase of radio equipment without the required permits from the National Telecommunications Commission, and payment of honoraria without appropriation. COA recommended refunds and the filing of administrative cases against involved officials, including petitioner Fe D. Laysa, the Regional Director.
Petitioner appealed, justifying the deviations. She argued that the Fishery Sector Program was a special research and development initiative funded by foreign institutions like the Asian Development Bank, not regular government appropriations. She contended that strict bureaucratic adherence to procurement rules would stifle the program’s objectives and that the government’s best interest was served as the transactions were advantageous. The COA en banc denied her appeal, prompting this petition for certiorari.
ISSUE
Whether the Commission on Audit committed grave abuse of discretion in affirming the audit findings and recommendations against petitioner despite her justifications.
RULING
The Supreme Court dismissed the petition and affirmed the COA decision. The Court held that the constitutional mandate and broad powers of COA to examine, audit, and settle all government accounts are precisely designed to ensure that all government funds, regardless of source, are managed and expended in accordance with law and regulations to prevent loss and ensure efficiency. The petitioner’s justifications, which essentially admitted non-compliance with COA rules and procurement laws while claiming the government’s interest was upheld, cannot override these mandatory legal safeguards.
The Court emphasized that findings of quasi-judicial agencies like COA, when supported by substantial evidence as in this case, are accorded respect and finality. The audit findings were substantiated, revealing clear violations of prescribed rules on bidding, documentation, and appropriations. The nature of the program’s funding does not exempt it from these fundamental fiscal controls. COA did not commit grave abuse of discretion; it properly performed its constitutional duty. The ultimate resolution of the officials’ administrative liability was correctly left for determination in the proper forum after trial.