GR 222710; (September, 2019) (Digest)
G.R. No. 222710, September 10, 2019
PHILIPPINE HEALTH INSURANCE CORPORATION, PETITIONER, VS. COMMISSION ON AUDIT, CHAIRPERSON MICHAEL G. AGUINALDO, DIRECTOR JOSEPH B. ANACAY AND SUPERVISING AUDITOR ELENA L. AGUSTIN, RESPONDENTS.
FACTS
The Philippine Health Insurance Corporation (PhilHealth) granted longevity pay to its officers and employees for the period January to September 2011, totaling P5,575,294.70, pursuant to Republic Act (R.A.) No. 7305 (Magna Carta of Public Health Workers). This grant was based on a 2000 Certification from the Department of Health (DOH) Secretary declaring PhilHealth personnel as public health workers and a 2001 Opinion from the Office of the Government Corporate Counsel (OGCC). The Commission on Audit (COA) issued a Notice of Disallowance (ND) on July 23, 2012, stating the payment lacked legal basis. PhilHealth appealed. The COA Corporate Government Sector affirmed the ND, ruling PhilHealth personnel are not principally tasked with health services. The COA Commission Proper dismissed PhilHealth’s subsequent petition for review for being filed out of time. The Supreme Court, in a July 24, 2018 Decision, denied PhilHealth’s petition for certiorari, upholding the dismissal on procedural grounds and substantively ruling that PhilHealth personnel are not public health workers entitled to longevity pay under R.A. No. 7305, and ordering refund. PhilHealth and the OGCC filed Motions for Reconsideration.
ISSUE
1. Whether PhilHealth personnel are public health workers entitled to longevity pay under R.A. No. 7305.
2. Assuming they are not, whether they should refund the disallowed amounts received in good faith.
RULING
The Supreme Court GRANTED the Motions for Reconsideration, REVERSED and SET ASIDE its July 24, 2018 Decision, and likewise REVERSED and SET ASIDE the Notice of Disallowance.
1. On the substantive issue, the Court held that the passage of R.A. No. 11223 (Universal Health Care Act) on February 20, 2019, during the pendency of the motions, constituted a “supervening event” that materially affected the issues of the case. Section 15 of R.A. No. 11223 explicitly provides that “all personnel of the Philippine Health Insurance Corporation shall be classified as public health workers in accordance with the pertinent provisions under Republic Act No. 7305…” The Court ruled that this new law conclusively settled the legal status of PhilHealth personnel as public health workers, thereby entitling them to corresponding benefits including longevity pay. Consequently, the disallowance of the longevity pay for lacking legal basis was reversed.
2. In light of the ruling that PhilHealth personnel are public health workers entitled to the benefit, the issue regarding refund based on good faith was rendered moot and unnecessary to discuss.