EN BANC
G.R. No. 227926, March 10, 2020
PROVINCE OF CAMARINES SUR, REPRESENTED BY GOVERNOR MIGUEL LUIS R. VILLAFUERTE, PETITIONER, V. THE COMMISSION ON AUDIT, RESPONDENT.
D E C I S I O N
REYES, J. JR., J.:
Under the said Notice of Disallowance, the following persons were found liable for the disbursements: ChanRoblesVirtualawlibrary
- The payments for the allowances of locally funded teachers were in violation of the provisions of Section 272 of RA 7160 which explicitly provide that the proceeds of Special Education Fund shall be allocated for the operation and maintenance of public schools and DECS-DBM-DILG Joint Circular No. 01 s of 1998 dated April 14, 1998, clarified under JC No. 01-A dated March 14, 2000 and JC No. 01-B dated June 25, 2001 which state that payments of salaries, authorized allowances and personnel-related benefits are only for hired teachers that handle new classes as extension of existing public elementary [or] secondary schools established and approved by DepEd;
- The allowances was taken up in the Special Education Fund (SEF) books as "Donations" (878) instead of taking it up to the General Fund books[;]
- No Memorandum of Agreement and Accomplishment Report attached[;]
- The payments of payrolls on JEV Nos. 200-08-10-185(1-5) and 200-08-10-188 were not approved by the Provincial Governor[;]
- The Journal Entry of Payrolls on JEV Nos. 200-08-09-165(12), 200-08-185(1-5) and 200-08-10-188 were not approved by the Provincial Accountant[;]
- The OBR on JEV No. 200-08-09-165(12) was not approved by the Provincial Budget Officer (PBO)[;]
- There were no certifications coming from the Head Teachers that the rec[i]pient-teacher indeed served in a particular school at a given time[;]
- There was no certification from the HRMO of the [p]rovince regarding the authenticity of each claim.9
On June 19, 2012, petitioner, through the Provincial Legal Officer, appealed the Notice of Disallowance to the Office of the Regional Director of COA-RO5 insisting that the payments of allowances and honoraria to locally funded teaching and non-teaching personnel were properly charged to the SEF in light of the pronouncement of the Court in Commission on Audit v. Province of Cebu11 and that the locally funded teachers actually rendered their services for calendar year 2008 as certified to by the Provincial Human Resource Management Officer (PFtRMO) and the Schools Division Superintendent (SDS) of Camarines Sur.12
Name Position/Designation Nature of Participation in the Transaction Nora Cariño OIC-HRMO For approving the transaction Lizerna Molave, Ma. Teresa Genova, Ruby Estefani Provincial Accountant For certifying that the supporting documents are complete Susan Laquindanum Assistant Provincial HRMO For certifying that charges to appropriation/allotment were necessary, lawful and under your direct supervision and that supporting documents were valid, proper and legal.10
WHEREFORE, premises considered, the motion for reconsideration is hereby DENIED for lack of merit. Accordingly, Commission on Audit Regional Office V Decision No. 2013-L-016 dated July 29, 2013 sustaining the Notice of Disallowance No. 2011-200-010 (08) dated November 15, 2011, on the payment of allowances/honoraria to locally hired temporary teachers and personnel of the Department of Education-Division of Camarines Sur in the total amount of P5,820,843.30, is AFFIRMED with FINALITY.18In finding the disallowance of the subject allowances/honoraria to be proper, the COA gave the same reasons as the COA-RO V when it affirmed the subject Notice of Disallowance. It held: ChanRoblesVirtualawlibrary
The afore-quoted DECS-DBM-DILG JCs provide that the salaries and allowances of teachers hired to handle extension classes are among the priority expenses chargeable to SEF. In this regard, such extension classes should be approved by the DECS (now DepEd) secretary upon the recommendation of the DepEd regional director and certified by the division superintendent as to the necessity and urgency of establishing extension classes in the LGUs and the number of pupils/students therein shall at least be 15.Undaunted, petitioner is now before this Court via the present Petition for Certiorari.
This Commission finds nothing in the records that the mandatory requirements for the establishment of extension classes were complied with, much less, were the teachers hired for the purpose of handling extension classes. Only the certification dated November 5, 2009 issued by Schools Division Superintendent Emma I. Cornejo attesting to the necessity and urgency of establishing extension classes in the elementary was presented.
With respect to the payment of allowances to the non-teaching personnel employed in the extension classes established by the DepEd-Division of Camarines Sur, the same is irregular since in the DECS-DBM-DILG JC No. 01-B dated June 25, 2001, only the salaries and authorized allowances of teachers hired to handle extension classes are chargeable against the SEF.19
A.
THE COA ACTED WITH GRAVE ABUSE OF DISCRETION AMOUNTING TO LACK OR EXCESS OF JURISDICTION WHEN IT FAILED TO CONSIDER PETITIONER'S COMPLIANCE WITH THE LOCAL GOVERNMENT CODE.B.
THE COA ACTED WITH GRAVE ABUSE OF DISCRETION AMOUNTING TO LACK OR EXCESS OF JURISDICTION WHEN IT FAILED TO CONSIDER THAT THE APPROVAL, RECOMMENDATION, AND CERTIFICATION REQUIREMENTS IN THE DECS-DBM-DILG JOINT CIRCULAR NO. 01-A CONSTITUTES AN INVALID EXERCISE OF THE ADMINISTRATIVE RULE-MAKING POWER, AND VIOLATES THE PRINCIPLE OF LOCAL AUTONOMY GRANTED TO LGUs BY THE LOCAL GOVERNMENT CODE.C.
THE COA ACTED WITH GRAVE ABUSE OF DISCRETION AMOUNTING TO LACK OR EXCESS OF JURISDICTION WHEN IT FAILED TO CONSIDER THAT THE JOINT CERTIFICATION BY THE ACTING HRMO AND SCHOOLS DIVISION SUPERINTENDENT SUFFICIENTLY MET THE CERTIFICATION REQUIREMENTS STATED IN THE AOM AND THE ND.20
SEC. 4. The President of the Philippines shall exercise general supervision over local governments. Provinces with respect to component cities and municipalities, and cities and municipalities with respect to component barangays shall ensure that the acts of their component units are within the scope of their prescribed powers and functions.The Court, in Pimentel v. Aguirre,32 further delineated the scope of Executive supervision over local government units as exclusive of control, or the power to restrain local government action.
This provision [Sec.4, Art. X of the 1987 Constitution] has been interpreted to exclude the power of control. In Mondano v. Silvosa, the Court contrasted the President's power of supervision over local government officials with that of his power of control over executive officials of the national government. It was emphasized that the two terms — supervision and control — differed in meaning and extent. The Court distinguished them as follows: ChanRoblesVirtualawlibraryWhile there may a valid issue with regard to the validity of the circular involved in this case in terms of how it impinges on the principle of local autonomy, the respondent correctly pointed out that administrative regulations, which were enacted by administrative agencies to interpret and implement the law they were entrusted to enforce, have the force of law. Thus, they cannot be collaterally attacked as there is a legal presumption of validity of these rules.In administrative law, supervision means overseeing or the power or authority of an officer to see that subordinate officers perform their duties. If the latter fail or neglect to fulfill them, the former may take such action or step as prescribed by law to make them perform their duties. Control, on the other hand, means the power of an officer to alter or modify or nullify or set aside what a subordinate officer ha[s] done in the performance of his duties and to substitute the judgment of the former for that of the latter.In Taule v. Santos, we further stated that the Chief Executive wielded no more authority than that of checking whether local governments or their officials were performing their duties as provided by the fundamental law and by statutes. He cannot interfere with local governments, so long as they act within the scope of their authority. "Supervisory power, when contrasted with control, is the power of mere oversight over an inferior body; it does not include any restraining authority over such body," we said.
In a more recent case, Drilon v. Lim, the difference between control and supervision was further delineated. Officers in control lay down the rules in the performance or accomplishment of an act. If these rules are not followed, they may, in their discretion, order the act undone or redone by their subordinates or even decide to do it themselves. On the other hand, supervision does not cover such authority. Supervising officials merely see to it that the rules are followed, but they themselves do not lay down such rules, nor do they have the discretion to modify or replace them. If the rules are not observed, they may order the work done or redone, but only to conform to such rules. They may not prescribe their own manner of execution of the act. They have no discretion on this matter except to see to it that the rules are followed.33 (Emphases supplied and citations omitted)
SEC. 1. Declaration of policy; creation of Special Education Fund. It is hereby declared to be the policy of the government to contribute to the financial support of the goals of education as provided by the Constitution. For this purpose, there is hereby created a Special Education Fund, hereinafter referred to as the Fund, to be derived from the additional tax on real property and from a certain portion of the taxes on Virginia-type cigarettes and duties on imported leaf tobacco, hereinafter provided for, which shall be expended exclusively for the following activities of the Department of Education: ChanRoblesVirtualawlibraryThe phrase which states that the SEF shall be expended for the organization and operation of such number of extension classes as may be needed to accommodate all children of school age desiring to enter Grade 1 shows that the salaries and allowances of non-teaching personnel which, as previously discussed, are indispensable to the organization and operation of extension classes, are also included in the list for which the SEF may be utilized. This must be so in light of the doctrine of necessary implication which states that every statutory grant of power, right or privilege is deemed to include all incidental power, right or privilege. In Department of Environment and Natural Resources v. United Planners Consultants, Inc.,38 the doctrine was explained, thus: ChanRoblesVirtualawlibrary(a) the organization and operation of such number of extension classes as may be needed to accommodate all children of school age desiring to enter Grade I, including the creation of positions of classroom teachers, head teachers and principals for such extension classes, which shall not exceed the standard requirements of the Bureau of Public Schools: Provided, That under equal circumstances, in the opening of such extension classes, priority shall be given to the needs of barrios;
No statute can be enacted that can provide all the details involved in its application. There is always an omission that may not meet a particular situation. What is thought, at the time of enactment, to be an all-embracing legislation may be inadequate to provide for the unfolding of events of the future. So-called gaps in the law develop as the law is enforced. One of the rules of statutory construction used to fill in the gap is the doctrine of necessary implication. The doctrine states that what is implied in a statute is as much a part thereof as that which is expressed. Every statute is understood, by implication, to contain all such provisions as may be necessary to effectuate its object and purpose, or to make effective rights, powers, privileges or jurisdiction which it grants, including all such collateral and subsidiary consequences as may be fairly and logically inferred from its terms. Ex necessitate legis. And every statutory grant of power, right or privilege is deemed to include all incidental power, right or privilege. This is so because the greater includes the lesser, expressed in the maxim, in eo plus sit, simper inest et minus.To construe the law otherwise would result in absurdity because the hiring of non-teaching personnel is but a necessary consequence to the maintenance, operation and organization of the extension classes.
Indeed, the operation and maintenance of public schools is lodged principally with the DECS. This is the reason why only salaries of public school teachers appointed in connection with the establishment and maintenance of extension classes, inter alia, pertain to the supplementary budget of the local school boards. Thus, it should be made clear that not every kind of personnel-related benefits of public school teachers may be charged to the SEF. The SEF may be expended only for the salaries and personnel-related benefits of teachers appointed by the local school board in connection with the establishment and maintenance of extension classes.40should not be taken to mean that the allowances/honoraria of non-teaching are not chargeable against the SEF because, as earlier pointed out, the allowances/honoraria of non-teaching personnel was not the issue in the said case.
Very truly yours, (SGD) EDGAR O. ARICHETA Clerk of Court |
Endnotes:
1Rollo, pp. 23-25.
2 Id. at 26-36.
3 Id. at 51-55.
4 Id. at 37-38.
5 Id. at 6, 156.
6 Id. at 7, 37.
7 Id. at 7, 101.
8 Supra note 4.
9Rollo, p. 37.
10 Id.
11 422 Phil. 519 (2001).
12Rollo, pp. 42-50.
13 Id. at 28-29.
14 Id. at 29.
15 Supra note 3.
16 Supra note 1.
17 Supra note 2
18Rollo, p. 35.
19 Id. at 34.
20 Id. at 12.
21 Id. at 156-157.
22 Id. at 13-14.
23 Id. at 15-17.
24 Id. at 158-159.
25 Id. at 17-19.
26 Id. at 159-161.
27 Id. at 105-107.
28 AN ACT CREATING A SPECIAL EDUCATION FUND TO BE CONSTITUTED FROM THE PROCEEDS OF AN ADDITIONAL REAL PROPERTY TAX AND A CERTAIN PORTION OF THE TAXES ON VIRGINIA-TYPE CIGARETTES AND DUTIES ON IMPORTED LEAF TOBACCO, DEFINING THE ACTIVITIES TO BE FINANCED, CREATING SCHOOL BOARDS FOR THE PURPOSE, AND APPROPRIATING FUNDS THEREFROM.
29Rollo, pp. 107-109.
30 Id. at 109-112.
31 Id. at 112-113.
32Pimentel, Jr. v. Aguirre, 391 Phil. 84 (2000).
33 Id. at 98-100.
34Samahan ng mga Progresibong Kabalaan (SPARK) v. Quezon City, 815 Phil. 1067, 1089-1090 (2017).
35Arceta v. Judge Mangrobang, 476 Phil. 106, 114-115 (2004).
36Geronimo v. Commission on Audit, G.R. No. 224163, December 4, 2018.
37Rollo, pp. 42-50.
38 754 Phil. 513, 530, citing Atienza v. Villarosa, 497 Phil. 689, 702-703 (2005).
39Commission on Audit v. Province of Cebu supra note 11.
40 Id. at 530.
LEONEN, J.:
I concur in the result. While the ponente eruditely discussed the ultimate issue of liability for refunding the disallowed disbursements, this Court should take this opportunity to clarify the nature of local autonomy and the allowable scope of Executive supervision over local government units.
The grant of local autonomy is Constitutionally mandated and allows local government units to make independent administrative determinations subject only to the Executive branch's general supervision. Thus, any regulations imposed on the exercise of local autonomy should not, in any way, amount to control.
Here, petitioner province of Camarines Sur questioned the Commission on Audit's disallowance of the honoraria and allowances paid by the provincial government to teaching and non-teaching personnel assigned to extension classes from July 2008 to October 2008. As basis for the disallowance, the Commission on Audit cited petitioner's failure to comply with the 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 pursuant to their administrative rule-making powers.1 These joint circulars imposed several prerequisites for the establishment of extension classes, particularly: (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) the certification by the Division Superintendent that extension classes were necessary and urgent.2
The joint circulars cited by the Commission on Audit impose conditions that contradict the concept of local autonomy, amounting to an exercise of control by the issuing agencies.
The constitutional mandate to ensure local autonomy refers to decentralization. In its broad or general sense, decentralization has two forms in the Philippine setting, namely: the decentralization of power and the decentralization of administration. The decentralization of power involves the abdication of political power in favor of the autonomous LGUs as to grant them the freedom to chart their own destinies and to shape their futures with minimum intervention from the central government. This amounts to self-immolation because the autonomous LGUs thereby become accountable not to the central authorities but to their constituencies. On the other hand, the decentralization of administration occurs when the central government delegates administrative powers to the LGUs as the means of broadening the base of governmental powers and of making the LGUs more responsive and accountable in the process, and thereby ensure their fullest development as self-reliant communities and more effective partners in the pursuit of the goals of national development and social progress. This form of decentralization further relieves the central government of the burden of managing local affairs so that it can concentrate on national concerns.4 (Citations omitted, emphasis supplied)Likewise, Pimentel, Jr. v. Aguirre5 clarified the reason for granting local autonomy, and qualified that this grant should remain bounded by national policy objectives.
Under the Philippine concept of local autonomy, the national government has not completely relinquished all its powers over local governments, including autonomous regions. Only administrative powers over local affairs are delegated to political subdivisions. The purpose of the delegation is to make governance more directly responsive and effective at the local levels. In turn, economic, political and social development at the smaller political units are expected to propel social and economic growth and development. But to enable the country to develop as a whole, the programs and policies effected locally must be integrated and coordinated towards a common national goal. Thus, policy-setting for the entire country still lies in the President and Congress. As we stated in Magtajas v. Pryce Properties Corp., Inc., municipal governments are still agents of the national government.6 (Citations omitted; Emphasis supplied)Thus, the Constitutional grant of local autonomy "does not make local governments sovereign within the state[,]"7 but reiterates the interdependence between central and local government agencies.8 But while regulations may validly be imposed on the exercise of local autonomy, such regulations are ultimately geared toward enhancing self-governance.9 Consequently, the devolution of administrative powers and functions inherent in local autonomy should not be rendered inutile by the need to seek prior approval from central government agencies. Rather, an autonomous local government should be able to promptly address matters in the exigencies of public service without undue restriction.
SECTION 4. The President of the Philippines shall exercise general supervision over local governments. Provinces with respect to component cities and municipalities, and cities and municipalities with respect to component barangays shall ensure that the acts of their component units are within the scope of their prescribed powers and functions. (Emphasis supplied)Pimentel v. Aguirre10 further delineated the scope of Executive Supervision over local government units as exclusive of control or the power to restrain local government action.
This provision has been interpreted to exclude the power of control. In Mondano v. Silvosa, the Court contrasted the President's power of supervision over local government officials with that of his power of control over executive officials of the national government. It was emphasized that the two terms—control and supervision—differed in meaning and extent. The Court distinguished them as follows: ChanRoblesVirtualawlibraryHence, executive supervision over local government units should not result in central agencies substituting the findings of a local government unit with their own. The same case of Pimentel provides that "[t]he purpose of the delegation [of administrative powers to local government units] is to make governance more directly responsive and effective at local levels."12... In administrative law, supervision means overseeing or the power or authority of an officer to see that subordinate officers perform their duties. If the latter fail or neglect to fulfill them, the former may take such action or step as prescribed by law to make them perform their duties. Control, on the other hand, means the power of an officer to alter or modify or nullify or set aside what a subordinate officer ha[s] done in the performance of his duties and to substitute the judgment of the former for that of the latter.In Taule v. Santos, we further stated that the Chief Executive wielded no more authority than that of checking whether local governments or their officials were performing their duties as provided by the fundamental law and by statutes. He cannot interfere with local governments, so long as they act within the scope of their authority. "Supervisory power, when contrasted with control, is the power of mere oversight over an inferior body; it does not include any restraining authority over such body," we said.11 (Citations omitted; Emphasis supplied)
A reading of MC No. 2010-138 shows that it is a mere reiteration of an existing provision in the LGC. It was plainly intended to remind LGUs to faithfully observe the directive stated in Section 287 of the LGC to utilize the 20% portion of the IRA for development projects. It was, at best, an advisory to LGUs to examine themselves if they have been complying with the law. It must be recalled that the assailed circular was issued in response to the report of the COA that a substantial portion of the 20% development fund of some LGUs was not actually utilized for development projects but was diverted to expenses more properly categorized as MOOE, in violation of Section 287 of the LGC. This intention was highlighted in the very first paragraph of MC No. 2010-138, which reads: ChanRoblesVirtualawlibraryIn Villafuerte, the assailed circulars were not deemed violations of local autonomy because they operated as mere guidelines for local government action. The requirements did not restrict or "compulsorily disallow" local government action.Section 287 of the Local Government Code mandates every local government to appropriate in its annual budget no less than 20% of its annual revenue allotment for development projects. In common understanding, development means the realization of desirable social, economic and environmental outcomes essential in the attainment of the constitutional objective of a desired quality of life for all. (Underscoring in the original)That the term development was characterized as the "realization of desirable social, economic and environmental outcome" does not operate as a restriction of the term so as to exclude some other activities that may bring about the same result. The definition was a plain characterization of the concept of development as it is commonly understood. The statement of a general definition was only necessary to illustrate among LGUs the nature of expenses that are properly chargeable against the development fund component of the IRA. It is expected to guide them and aid them in rethinking their ways so that they may be able to rectify lapses in judgment, should there be any, or it may simply stand as a reaffirmation of an already proper administration of expenses.
The same clarification may be said of the enumeration of expenses in MC No. 2010-138. To begin with, it is erroneous to call them exclusions because such a term signifies compulsory disallowance of a particular item or activity[.]16 (Citations omitted; Emphasis and underscoring supplied)
Contrary to the petitioners' posturing, however, the enumeration was not meant to restrict the discretion of the LGUs in the utilization of their funds. It was meant to enlighten LGUs as to the nature of the development fund by delineating it from other types of expenses. It was incorporated in the assailed circular in order to guide them in the proper disposition of the IRA and avert further misuse of the fund by citing current practices which seemed to be incompatible with the purpose of the fund. Even then, LGUs remain at liberty to map out their respective development plans solely on the basis of their own judgment and utilize their IRAs accordingly, with the only restriction that 20% thereof be expended for development projects. They may even spend their IRAs for some of the enumerated items should they partake of indirect costs of undertaking development projects. In such case, however, the concerned LGU must ascertain that applicable rules and regulations on budgetary allocation have been observed lest it be inviting an administrative probe.19 (Citations omitted; Emphasis and underscoring supplied)While the requirements imposed by administrative issuances may not have been intended to supplant local government judgment, the issue of whether supervision has lapsed into control should not be a question of intent but of effect. The ponencia recognized a valid issue regarding the validity of Joint Circular No. 01-A, but opted to forego a ruling thereon based on procedural grounds.20 However, a perusal of the questioned circular reveals that it effectively prohibits the provincial government from holding or creating extension classes without prior approval and recommendation by the concerned central government agencies. In fact, the Commission on Audit disallowed the disbursements precisely because certain approvals from central government agencies were not procured.21
The defense of good faith is, therefore, no longer available to members of governing boards and officials who have approved the disallowed allowance or benefit. Neither would the defense be available to the rank and file should the allowance or benefit be the subject of collective negotiation agreement negotiations. Furthermore, the rank and file's obligation to return shall be limited only to what they have actually received. They may, subject to Commission on Audit approval, agree to the terms of payment for the return of the disallowed funds. For the approving board members or officers, however, the nature of the obligation to return—whether it be solidary or not—depends on the circumstances.24 (Citations omitted, emphasis supplied)Rotoras discussed the liability of members of the approving board to reimburse the amounts they disbursed, and subsequently received, after such disbursements were disallowed by the Commission on Audit. There, this Court did away with the defense of good faith and ordered the approving authorities to reimburse the amounts they received pursuant to the State's policy against unjust enrichment.
Nonetheless, there have been instances when, regardless of the alleged good or bad faith of the responsible officers and recipients, this Court ordered the refund of the amounts received. Applying the rule against unjust enrichment, it required public officers to return the disallowed benefits, considering them as trustees of funds which they should return to the government....Thus, the issue of good faith in the release of disallowed disbursements is no longer relevant to the liability for reimbursement.
....
The rule against unjust enrichment, along with the treatment of recipients of disallowed benefits as trustees in favor of government, was applied in the recent case of Dubongco v. Commission on Audit. There, this Court declined to ascribe good or bad faith to the recipients of the disallowed collective negotiation agreement incentive. It found that since they had no valid claim to the benefits, they cannot be allowed to retain them, notwithstanding the absence of fraud in their receipt: ChanRoblesVirtualawlibraryEvery person who, through an act of performance by another, or any other means, acquires or comes into possession of something at the expense of the latter without just or legal ground, shall return the same to him. Unjust enrichment refers to the result or effect of failure to make remuneration of, or for property or benefits received under circumstances that give rise to legal or equitable obligation to account for them. To be entitled to remuneration, one must confer benefit by mistake, fraud, coercion, or request. Unjust enrichment is not itself a theory of reconveyance. Rather, it is a prerequisite for the enforcement of the doctrine of restitution. Thus, there is unjust enrichment when a person unjustly retains a benefit to the loss of another, or when a person retains money or property of another against the fundamental principles of justice, equity and good conscience. The principle of unjust enrichment requires two conditions: (1) that a person is benefited without a valid basis or justification; and (2) that such benefit is derived at the expense of another. Conversely, there is no unjust enrichment when the person who will benefit has a valid claim to such benefit.25 (Citations omitted, emphasis supplied)
Endnotes:
1 Ponencia, p. 2.
2 Id. at 4.
3Mandanas v. Ochoa, Jr., G.R. No. 199802 & 208488 (Decision), July 3, 2018, 869 SCRA 440 [Per J. Bersamin, En Banc].
4 Id. at 485.
5Pimentel v. Aguirre, 391 Phil. 84 (2000) [Per J. Panganiban, En Banc].
6 Id. at 102.
7Villafuerte v. Robredo, 749 Phil. 841, 865 (2014) [Per J. Reyes, En Banc].
8 Id. citing Ganzon v. Court of Appeals, 277 Phil. 311 (1991) [Per J. Sarmiento, En Banc].
9 Id.
10 391 Phil. 84 (2000) [Per J. Panganiban, En Banc].
11 Id. at 98-99.
12 Id. at 102.
13 252 Phil. 813 (1989) [Per J. Sarmiento, En Banc].
14 Id. at 825.
15 749 Phil. 841 (2014) [Per J. Reyes, En Banc].
16 Id., at 862-863.
17Ganzon v. Court of Appeals, 277 Phil. 311, 329 (1991) [Per J. Sarmiento, En Banc].
18Villafuerte v. Robredo, 749 Phil. 841, 864 (2014) [Per J. Reyes, En Banc].
19 Id. at 863-864.
20Ponencia, pp. 9-11.
21 Id. at 4.
22 LOCAL GOVT. CODE, Sec. 99(a); Republic Act No. 5447, sec. 6(a).
23 G.R. No. 211999, October 21, 2019 [Per J. Leonen, En Banc].
24 Id. at 23-24.
25 Id. at 19-22.chanRoblesvirtualLawlibrary