GR 263060; (July, 2024) (Digest)
G.R. No. 263060, July 22, 2024
PINAG-ISANG LAKAS NG MGA MANGGAGAWA SA LRT (PIGLAS), ET AL., PETITIONERS, VS. COMMISSION ON AUDIT (COA), LIGHT RAIL TRANSIT AUTHORITY (LRTA) AND METRO TRANSIT ORGANIZATION, INC. (MTOI), RESPONDENTS.
FACTS
This is a Petition for Certiorari under Rule 64, in relation to Rule 65, of the Rules of Court assailing the Decision dated December 17, 2020, and the Resolution dated January 28, 2022, of the Commission on Audit (COA) in COA C.P. Case No. 2018-0559. The petitioners are members of the Pinag-Isang Lakas ng mga Manggagawa sa LRT (PIGLAS) union. The case involves claims for payment of Collective Negotiation Agreement (CNA) incentives for the years 2004 to 2009 against the Light Rail Transit Authority (LRTA) and Metro Transit Organization, Inc. (MTOI). The factual antecedents detail a history of labor disputes and litigation between the parties concerning these CNA incentives. The petitioners sought the release of these incentives, which were initially disallowed by the COA. The COA, in its assailed Decision, denied the petitioners’ claim for payment, finding no legal basis to hold the government liable for the payment of CNA incentives to employees of a private contractor (MTOI). The COA also ruled that the claim had already prescribed. The petitioners filed a Motion for Reconsideration, which was denied by the COA in its Resolution dated January 28, 2022.
ISSUE
The core issue revolves around the propriety of the COA’s denial of the petitioners’ claim for CNA incentives, specifically whether the COA committed grave abuse of discretion in ruling that there is no legal basis for the claim and that the claim had prescribed.
RULING
The Supreme Court dismissed the Petition. The Court held that the petitioners failed to sufficiently show that the COA committed grave abuse of discretion in rendering the assailed Decision and Resolution. The Court found that the COA’s findings were supported by substantial evidence and applicable laws and jurisprudence. The Court emphasized that the power to disallow audit transactions is vested in the COA, and its decisions are generally accorded respect and finality. The Court also noted that the claim for CNA incentives pertained to a period covered by a service contract between LRTA and MTOI, a private entity, and that the government cannot be held liable for the contractual obligations of a private contractor. Furthermore, the Court agreed with the COA’s finding that the claim had prescribed, as the demand for payment was made well beyond the reasonable period from the accrual of the claim. The Petition was dismissed for lack of merit.