G.R. No. 227926 , March 10, 2020
PROVINCE OF CAMARINES SUR, REPRESENTED BY GOVERNOR MIGUEL LUIS R. VILLAFUERTE, PETITIONER, VS. THE COMMISSION ON AUDIT, RESPONDENT.

FACTS

The Province of Camarines Sur questioned the Commission on Audit’s disallowance of honoraria and allowances paid by the provincial government to teaching and non-teaching personnel assigned to extension classes from July 2008 to October 2008. The Commission on Audit based its disallowance on the provincial government’s failure to comply with joint circulars issued by the Department of Education, Culture and Sports (now the Department of Education), the Department of Budget and Management, and the Department of the Interior and Local Government. These joint circulars imposed prerequisites for establishing extension classes, including: (1) the prior recommendation of the Department of Education, Culture and Sports Regional Director; (2) the approval of the proposed extension classes issued by the Department of Education, Culture and Sports Secretary; and (3) a certification by the Division Superintendent that extension classes were necessary and urgent.

ISSUE

Whether the joint circulars issued by the national government agencies, which imposed prerequisites for the establishment of extension classes by the local government, contradict the constitutional concept of local autonomy by amounting to an exercise of control rather than permissible general supervision.

RULING

The Separate Concurring Opinion clarifies that the constitutional grant of local autonomy allows local government units to make independent administrative determinations subject only to the Executive branch’s general supervision, which excludes the power of control. The joint circulars in question impose conditions that contradict this concept of local autonomy. By requiring prior recommendation and approval from national agency officials (the DECS Regional Director and Secretary) and a certification of necessity from the Division Superintendent, the circulars effectively allow central government agencies to substitute their own judgment for that of the local government unit. This amounts to control, not mere supervision. Supervision means overseeing to ensure subordinate officers perform their duties, while control means the power to alter, modify, nullify, or set aside a subordinate’s actions and substitute the superior’s judgment. The purpose of local autonomy is to make governance more responsive and effective at local levels and to relieve the central government of managing local affairs. Therefore, regulations imposed on the exercise of local autonomy must be reasonable and should not give central agencies the power to restrict or substitute local government actions. The concurring opinion concludes that the grant of local autonomy should give local government units sufficient discretion to act on matters of local importance without undue interference.