GR 185812; (January, 2015) (Digest)
G.R. No. 185812 , January 13, 2015
Maritime Industry Authority vs. Commission on Audit
FACTS
The Maritime Industry Authority (MARINA), an attached agency of the Department of Transportation and Communication, granted various allowances and incentives to its officers and employees starting January 2001. This grant was based on a memorandum dated February 10, 2000, from the MARINA Administrator to then President Joseph Estrada, which recommended the approval and/or restoration of several financial incentives. The memorandum was allegedly stamped “approved” and signed by the President on October 16, 2000. The allowances included per diems and commutable allowance for Board members, rice subsidy, medical allowance, reimbursable representation allowance, performance incentives, economic assistance, hearing allowance, and birthday/employment anniversary allowances. The Resident Auditor of MARINA issued Notices of Disallowance for these allowances from January to May 2001, totaling Php 5,565,445.02, on the grounds that they constituted prohibited double compensation and were integrated into standardized salaries under the Compensation and Position Classification Act of 1989 ( Republic Act No. 6758 ). MARINA’s subsequent appeals to the Commission on Audit’s Legal and Adjudication Office and the Commission on Audit proper were denied. The COA held that the disallowed allowances were integrated into standardized salary rates by law and that the President’s alleged approval did not constitute the “law” required as an exception to the prohibition. MARINA filed a petition for certiorari before the Supreme Court.
ISSUE
Whether the allowances or incentives granted to the officers and employees of the Maritime Industry Authority have a legal basis.
RULING
The Supreme Court denied the petition, finding no grave abuse of discretion on the part of the Commission on Audit. The Court held that the disallowed allowances and incentives were deemed integrated into the standardized salary rates prescribed under Section 12 of Republic Act No. 6758 (the Salary Standardization Law). The alleged approval by the President of the memorandum recommending the grant of these benefits did not qualify as a “law” that could authorize such additional compensation, as required by the constitutional prohibition against double compensation. The Court affirmed that the Commission on Audit acted within its jurisdiction in disallowing the payments, as they lacked the requisite legal basis.