GR 247784; (September, 2021) (Digest)
G.R. No. 247784, September 28, 2021
Philippine Health Insurance Corporation, Petitioner, vs. Commission on Audit (COA) and Mr. Michael G. Aguinaldo in his capacity as COA Chairman, Respondents.
FACTS
On December 20, 2011, the President and CEO of the Philippine Health Insurance Corporation (PhilHealth) issued Office Order No. 0096, which granted its officers and employees the benefits under Republic Act No. 7305 (the Magna Carta of Public Health Workers), effective January 1, 2012. This grant was confirmed by the PhilHealth Board of Directors in its Resolution No. 1584 dated January 31, 2012. Subsequently, the Commission on Audit (COA) issued two Notices of Disallowance (ND) for calendar year 2012, disallowing the payment of hazard pay and subsistence and laundry allowances to PhilHealth personnel, totaling P91,156,377.93. PhilHealth appealed the disallowances to the COA Cluster A Corporate Government Sector, which denied the appeals. PhilHealth then elevated the case to the COA Proper via a petition for review. The COA Proper, in its Decision No. 2015-419, initially dismissed the petition for being filed out of time but later reconsidered and decided on the merits. In its Decision No. 2019-161, the COA affirmed the disallowances, ruling that PhilHealth personnel who are not directly involved in rendering health services are not considered health workers entitled to such benefits under R.A. No. 7305, as PhilHealth’s function is to provide health insurance coverage, not direct health services.
ISSUE
Whether PhilHealth’s officers and employees are entitled to hazard pay and subsistence and laundry allowances under the Magna Carta of Public Health Workers (R.A. No. 7305).
RULING
Yes. The Supreme Court granted the petition and set aside the COA decisions and the Notices of Disallowance. The Court ruled that Republic Act No. 11223 (the Universal Health Care Act), which explicitly classifies all PhilHealth personnel as public health workers in accordance with R.A. No. 7305, is a curative statute that applies retrospectively. Citing its 2019 ruling in Philippine Health Insurance Corporation v. Commission on Audit, the Court held that R.A. No. 11223 remedied the prior legal ambiguity and settled that all PhilHealth personnel are public health workers entitled to the benefits under R.A. No. 7305, including hazard allowance (Section 21), subsistence allowance (Section 22), and laundry allowance (Section 24). Consequently, the disallowance of these benefits for calendar year 2012 was erroneous.