G.R. No. L-47051 July 29, 1988
BLUE BAR COCONUT PHILIPPINES, ET AL., petitioners, vs. THE HONORABLE FRANCISCO S. TANTUICO, JR., Acting Chairman of the Commission on Audit; and DR. GREGORIO YU, Auditor of the Philippine Coconut Authority, respondents.

FACTS

Petitioners are coconut oil millers and end-users who acted as levy-collectors and remitters for the Coconut Consumers Stabilization Fund (CCSF) established under Presidential Decree No. 276. The Philippine Coconut Authority (PCA) Governing Board issued Resolution No. 01-75 on January 8, 1975, reducing the levy rate, effective January 11, 1975. Subsequently, the Commission on Audit (COA), through respondent Acting Chairman Francisco Tantuico, Jr., initiated a special audit of the petitioners’ CCSF collections and subsidy receipts. The audit found alleged short levies and overpaid subsidies. The COA then directed PCA officials to collect these amounts and to apply future subsidy claims against any deficiencies.
Petitioners contested these findings, arguing that the COA refused to recognize the validity of the PCA Board’s resolution reducing the levy rate, which justified their remittance calculations. They sought payment of their pending subsidy claims from the PCA. However, the PCA Auditor, respondent Dr. Gregorio Yu, refused to act, deferring to the COA Chairman. The petitioners thus filed this special civil action for certiorari, prohibition, and mandamus to annul the COA’s actions, prevent further collection, and compel payment of their subsidies.

ISSUE

Whether the respondents, the COA Acting Chairman and the PCA Auditor, committed grave abuse of discretion amounting to lack or excess of jurisdiction in their audit findings and subsequent orders regarding the petitioners’ CCSF levies and subsidies.

RULING

The Supreme Court dismissed the petition. The Court held that the petitioners failed to demonstrate that the COA’s acts constituted grave abuse of discretion. The audit function of the COA is a constitutional mandate, and its findings on technical and intricate fiscal matters command respect. The Court emphasized the policy of judicial non-interference with administrative agency determinations, especially those involving specialized knowledge and technical facts, absent a clear showing of arbitrariness or palpable error.
The legal logic is anchored on the doctrine of primary jurisdiction and the presumption of regularity in the performance of official duty. The COA, as the constitutional auditor, possesses the specialized competence to examine government funds, including trust funds like the CCSF. The petitioners’ mere disagreement with the audit findings, without proving through concrete evidence that the COA acted capriciously or whimsically, is insufficient to warrant judicial intervention. The Court reiterated that certiorari lies only for jurisdictional errors from grave abuse of discretion, which was not substantiated here. The proper recourse for petitioners was to exhaust administrative appeals within the COA framework, not to directly invoke the Court’s extraordinary writs.