GR 242764; (January, 2021) (Digest)
G.R. No. 242764, January 19, 2021
Theo-Pam Trading Corporation, Petitioner, vs. Bureau of Plant Industry and the Commission on Audit, Respondents.
FACTS
Theo-Pam Trading Corporation (Theo-Pam) filed a Money Claim before the Commission on Audit (COA) Proper against the Bureau of Plant Industry (BPI) for payment of various laboratory chemicals amounting to P2,361,060.00. Between May and October 2009, BPI issued four purchase orders (POs) to Theo-Pam, which were signed and approved by BPI Director Joel S. Rudinas and the head of the requisitioning office, and certified for fund availability by the Budget Officer. Theo-Pam delivered the chemicals and issued corresponding wholesale invoices. Personnel from BPI’s National Pesticide Analytical Laboratory (NPAL) signed two of the invoices, acknowledging receipt of the articles in good order. Despite demands, BPI failed to pay. BPI Director Larry Lacson formed an Inspection/Verification Team, which concluded there was substantial evidence, including delivery receipts and staff testimonies, that the chemicals were delivered and consumed, and recommended immediate settlement. BPI later denied actual delivery in its Answer to the claim. The COA Proper denied Theo-Pam’s claim, prompting this Petition for Certiorari.
ISSUE
Whether the COA Proper committed grave abuse of discretion in denying Theo-Pam’s Money Claim for payment of delivered chemicals.
RULING
Yes. The Supreme Court granted the petition, reversed the COA Proper’s Decision and Resolution, and directed BPI to pay Theo-Pam the principal amount of P2,361,060.00. The Court found that the COA Proper disregarded the evidence establishing BPI’s receipt and acceptance of the delivered chemicals. The POs, invoices, certifications from BPI personnel, the Team Report confirming delivery and consumption, and BPI’s own communications acknowledging the obligation and intent to pay constituted clear proof of delivery and receipt. BPI’s belated denial of delivery, unsupported by evidence, could not overcome these admissions and the presumptions of regularity and fairness in the transactions. The COA’s denial, based on alleged procedural lapses in the procurement process, was a grave abuse of discretion as these lapses did not negate the government’s obligation to pay for goods actually delivered, received, accepted, and consumed.