EN BANC
G.R. No. 218383, January 05, 2021
THE OFFICERS AND EMPLOYEES OF ILOILO PROVINCIAL GOVERNMENT HEREIN REPRESENTED BY ATTY. EDGAR CLAUDIO O. SUMIDO, Petitioners, v. THE COMMISSION ON AUDIT, CHAIRPERSON MA. GRACIA M. PULIDO-TAN, COMMISSIONER HEIDI L. MENDOZAAND COMMISSIONER JOSE A. FABIA, Respondents.
D E C I S I O N
ZALAMEDA, J.:
Officials and employees should endeavor to keep abreast of laws, rules and regulations, as well as all disallowed transactions received by their office, to avoid illegal, irregular, unnecessary, excessive, extravagant or unconscionable transactions. The grant and approval of a benefit more than five (5) times the amount given by other government offices without ensuring compliance with budgetary rules is a clear showing of gross negligence characterized by having a want of the slightest care and a conscious indifference to the consequences of his or her acts.
Petitioners appealed the disallowance before the COA Regional Office and argued that the Provincial Government of Iloilo acted in good faith in implementing Appropriation Ordinance No. 2009-06 passed by the Sangguniang Panlalawigan of Iloilo. The recipients, who received the benefit in good faith, should not be compelled to refund the same. Moreover, even if the province exceeded its Personal Services limitation, the disallowance should not cover the total amount since other waived items (leave credits, terminal leaves and subsistence allowance) must be considered in computing Personal Services limitation.9
Name and Position Participation in the Transaction Niel D. Tupas, Sr. - Provincial Governor For approving payment; Rolex T. Suplico - Provincial Vice Governor / Sangguniang Panlalawigan (SP) - Presiding Officer For passing the appropriation despite excess in Personal Services limitation; Oscar S. Garin, Jr. - Floor Leader For passing the appropriation despite excess in Personal Services limitation; Macario N. Napulan - SP Member For passing the appropriation despite excess in Personal Services limitation; June S. Mondejar - SP Member For passing the appropriation despite excess in Personal Services limitation; Rodolfo V. Cabado - SP Member For passing the appropriation despite excess in Personal Services limitation; Arthur R. Defensor, Jr. - SP Member For passing the appropriation despite excess in Personal Services limitation; Mariano M. Malones, Sr. - SP Member For passing the appropriation despite excess in Personal Services limitation; George P. Demaisip - SP Member For passing the appropriation despite excess in personal services limitation; Cecilia A. Colada - SP Member (FSBM President) For passing the appropriation despite excess in Personal Services limitation; Guisseppe Karl D. Gumban - SP Member (PPSK President) For passing the appropriation despite excess in Personal Services limitation; Lyd P. Tupas - Provincial Accountant For certifying as to completeness of documents; Corazon Estelita S. Beloria - Asst. Prov. Treasurer For certifying as to availability of funds; Elena D. Lim - Budget Officer For certifying as yo availability of appropriation; Salvador P. Cabaluna, III Provincial Legal Officer For certifying that the officials and employees are entitled to Productivity Enhancement incentive (PEI); All other payees as stated in ND Nos. 2010-06-101(09) to 2010-85-101(09), all dated 28 September 20108 For being recepients of the disallowed benefits.
WHEREFORE, premises considered, the instant petition for review is hereby DENIED for lack of merit. Accordingly, COA Region VI Decision No. 2012-021 dated August 28, 2012 is AFFIRMED.12chanRoblesvirtualLawlibraryCOA Proper reiterated the need for the LGU to follow the Personal Services limitation in granting PEI to its employees. Further, COA Proper brushed aside petitioners' claim of good faith since they are presumed to know the relevant provisions of the law.13
a) The Commission on Audit gravely erred in disallowing payments made by the Iloilo Provincial Government to its officials and employees for their Productivity Enhancement Incentive for Calendar year 2009 and order the refund of the full amount without considering the amount in excess and the waived items.Petitioners assert the legality of the grant of PEI to the officials and employees of the Province of Iloilo by virtue of a validly passed appropriations ordinance. They also claim good faith in the receipt of the benefit to avoid liability for the refund of the disallowed amounts.16
b) The COA gravely erred in its findings that the officials and employees of Iloilo Provincial Government cannot be considered in goodfaith (sic) when the[y] received the subject incentive.
SEC. 3. Time to file petition. - The petition shall be filed within thirty (30) days from notice of the judgment or final order or resolution sought to be reviewed. The filing of a motion for new trial or reconsideration of said judgment or final order or resolution, if allowed under the procedural rules of the Commission concerned, shall interrupt the period herein fixed. If the motion is denied, the aggrieved party may file the petition within the remaining period, but which shall not be less than five (5) days in any event, reckoned from notice of denial. (Emphasis supplied)Clearly, the thirty-day reglementary period to assail the decision of COA Proper is merely interrupted by the filing of a motion for reconsideration. After receipt of the denial of the motion, petitioners are not given a fresh period of thirty (30) days but are allowed to file the petition within the remaining period, which shall not be less than five (5) days in any event.
2.0 Grant of the PEIxxxx
2.1 The respective sanggunian may grant the PEI to local government personnel depending on the financial capability of the local government unit (LGU). The PEI shall be in lieu of the Additional Benefit/Extra Cash Gift authorized in previous years.
3.0 Funding Source
The PEI for local government personnel shall be charged against LGU funds, subject to the budgetary conditions and Personal Services limitation in LGU budgets pursuant to Sections 325(a) and 331(b) of R.A. No. 7160.
Meanwhile, Sections 325(a) of RA 7160 provides:
SECTION 325. General Limitations. — The use of the provincial, city, and municipal funds shall be subject to the following limitations:
(a) The total appropriations, whether annual or supplemental, for personal services of a local government unit for one (1) fiscal year shall not exceed forty-five percent (45%) in the case of first to third class provinces, cities and municipalities, and fifty-five percent (55%) in the case of fourth class or lower, of the total annual income from regular sources realized in the next preceding fiscal year. The appropriations for salaries, wages, representation and transportation allowances of officials and employees of the public utilities and economic enterprises owned, operated, and maintained by the local government unit concerned shall not be included in the annual budget or in the computation of the maximum amount for personal services. The appropriations for the personal services of such economic enterprises shall be charged to their respective budgets;
x x x x (Emphasis supplied)
Petitioners, in attacking the validity of the disallowance, points to the failure of the CO A to consider other waived items which are not included in the computation of the Personal Service limitation. They, thus, present the following computation:
Total income from revenue sources realized in 2007Php 1,031,451,660.91 Personal Services (PS) Limitation Percentage 45% Allowable PS Level/CostPhp 464.153.247.41 Actual PS Cost before PEI-Php 502,854,446.31 Allowable PS Cost 464,153,247.41 Excess of Actual PS over Allowable PS Level/CostPhp 8,701,198.90
Excess over PS limitation Php 38,701,198.90 Less: Waived items 16,717,234.34 Excess over Personal Services 21,983.964.5623
It will be noted that before the payment of the PEI of P102,700,000.00 PGI had already incurred an excess of P38,701,198.90 over the allowable PS cost and this includes the PS costs for waived items amounting to P16,717,234.34 (i.e. leave credits, terminal leave and subsistence allowance of health workers). Even if the amount of waived items is deducted from the actual PS cost (P502,854,446.31 - P16,717,234.34) the adjusted actual cost of P486,137,211.97 still exceeds by P21,983,964.56 the allowable PS of P464,153,247.41. Thus, PGI was already precluded form incurring additional PS costs or benefits like PEI.24The factual findings of administrative bodies charged with their specific field of expertise, are afforded great weight by the courts. In the absence of substantial showing that such findings were made from an erroneous estimation of the evidence presented, they are conclusive, and in the interest of stability of the governmental structure, should not be disturbed.25 And, the COA did not act with,grave abuse of discretion in disallowing the payment of PET to the employees of the Province of Iloilo for CY 2009.
These guidelines were formulated after careful consideration of Sections 3827 and 39,28 in relation to Section 43,29 of the Administrative Code30 whereby government officials who approved and certified the grant of disallowed benefits are held solidarily liable to return the amount thereof only when they acted in evident bad faith, with malice, or if they were grossly negligent in the performance of their official duties. Simply stated, "public officers are accorded with the presumption of regularity in the performance of their official functions — [t]hat is, when an act has been completed, it is to be supposed that the act was done in the manner prescribed and by an officer authorized by law to do it."31
- If a Notice of Disallowance is set aside by the Court, no return shall be required from any of the persons held liable therein.
- If a Notice of Disallowance is upheld, the rules on return are as follows:
a. Approving and certifying officers who acted in good faith, in regular performance of official functions, and with the diligence of a good father of the family are not civilly liable to return consistent with Section 3 8 of the Administrative Code of 1987.
b. Approving and certifying officers who are clearly shown to have acted in bad faith, malice, or gross negligence are, pursuant to Section 43 of the Administrative Code of 1987, solidarity liable to return only the net disallowed amount which, as discussed herein, excludes amounts excused under the following sections 2c and 2d.
c. Recipients — whether approving or certifying officers or mere passive recipients — are liable to return the disallowed amounts respectively received by them, unless they are able to show that the amounts they received were genuinely given in consideration of services rendered.
d. The Court may likewise excuse, the return of recipients based on undue prejudice, social justice- considerations, and other bona fide exceptions as it. may determine on a case to case basis.
Furthermore, granting arguendo that the municipality's budget adopted the incorrect salary rates, this error or mistake was not in any way indicative of bad faith. Under prevailing jurisprudence, mistakes committed by a public officer are not actionable, absent a clear showing that he was motivated by malice or gross negligence amounting to bad faith. It does not simply connote bad moral judgment or negligence. Rather, there must be some dishonest purpose or some moral obliquity and conscious doing of a wrong, a breach of a sworn duty through some motive or intent, or ill will. It partakes of the nature of fraud and contemplates a state of mind affirmatively operating with furtive design or some motive of self-interest or ill will for ulterior purposes, x x x32In this case, the Court finds no justification for the failure of the approving and certifying officials to observe the province's Personal Services limitation cap. They failed to faithfully discharge their respective duties and exercise the required diligence resulting to the illegal and excessive disbursements paid to the employees of the Province of Iloilo. Even if the grant of PEI was not for a dishonest purpose, the patent disregard of the issuance by the DBM on the Personal Services limitation constitutes gross negligence, making them liable for the refund thereof.33
This was echoed in DBM Local Budget Circular No. 2009-93 but with clarification that the benefit shall be in lieu of the Additional Benefit/Extra Cash Gift authorized in previous years. Evidently, the law specified for a fixed amount of Php 10,000.00 for other branches and offices of the government while the LGLIs were given a free hand in determining the suitable amount of PEI depending on their financial capability. Nonetheless, the rate given to other offices should have prompted the officials and officers of the province to initially review the conditions for the grant and carefully ensure compliance with the budgetary rules. Their failure to do so demonstrates a callous frame of mind without care of the financial health of the Province of Iloilo. Their indifference to the financial state of the province is made more evident by the amount in excess of the province's Personal Services limitation, which is already at Php38,701,198.90 even before the grant of PEL With the additional disbursement of Php 102.7M due to the subject benefit, the excess of the province's Personal Services limitation rose up to roughly Php 141.4 mill ion.
SECTION 3. PEI for Employees of LGUs. Employees in the local government units (LGUs) may also be granted PEI by their respective sanggunian, depending on the LGU financial capability, chargeable to local government funds, subject to the Personal Services limitation in their respective local government budgets under RA No. 7160 and subject further to the conditions in Section 1 hereof. The PEI shall be in lieu of the Additional Benefit/Extra Cash Gift authorized in previous years.
Moreover, a similar allowance granted in 2002 and was disallowed in 2004 for being violative of the PS cap limitation under Section 325(a) of RA 7160, was sustained by the Supreme Court, thus paving way for the issuance of a Final Order of Adjudication (now the COA Order of Execution under the 2009 Revised Rules of Procedure of the COA) by the General Counsel of COA on March 18, 2009. Clearly, the Province of Iloilo was well aware at the time of payment of the PEI in December, 2009 that the same benefit may be disallowed by the Auditors of the COA for the reason that the payment thereof is in violation of Section 325(a) of RA 7160.37This argument is well-taken. A prior disallowance based on the same cause should have drawn the attention of the approving and certifying officers to be more vigilant and circumspect especially in cases pertaining to the same type of transactions. Such caveat applies even more in this case where the approving and certifying officers intended to grant a larger amount of benefit than the standard. As noted by Justice Caguioa, the approving and certifying officers should have also been guided by the Court's pronouncement in Lumayna v. Commission on Audit,38 where We disallowed the salary increase of municipal personnel since the municipality therein had already exceeded its Personal Services limitation. The following badges of whether an authorizing or certifying officer exercised the diligence of a good father of a family are also instructive:39chanrobleslawlibrary
xxx For one to be absolved of liability the following requisites [may be considered]: (1) Certificates of Availability of Funds pursuant to Section 40 of the Administrative Code, (2) In-house or Department of Justice legal opinion, (3) that there is no precedent disallowing a similar case in jurisprudence, (4) that it is traditionally practiced within the agency and no prior disallowance has been issued, [or] (5) with regard the question of law, that there is a reasonable textual interpretation on its legality. 40 (Emphasis supplied)Verily, the Court in Silang v. Commission on Audit,41 dismissed the claim of good faith by the approving officials and those directly involved in the release of the illegal disbursement for their failure to follow the requirements under applicable policies in relation to the valid grant of therein subject incentive. They are duty bound to have full knowledge of basic procedure as part of their shared fiscal responsibility under the law.
Section 305. Fundamental Principles. — The financial affairs, transactions, and operations of local government units shall be governed by the following fundamental principles:We, likewise, recognize the cases cited by Justice Caguioa as examples of how the patent disregard of existing law or rules overcomes the presumption of good faith and necessitates the officers to return the disallowed amount:chanroblesvirtualawlibraryx x x
(1) Fiscal responsibility shall be shared by all those exercising authority over the financial affairs, transactions, and operations of the local government units;43
Casal v COA:44Undoubtedly, there is a clear showing of gross negligence on the part of herein approving and certifying officers for their failure to exercise the slightest care and with a conscious indifference in the discharge of their duties coupled with the lack of any badge of good faith available to their case. Therefore, the Court holds them solidarily liable for the disallowed amounts pursuant to Section 43, Chapter 5, Book IV of the Administrative Code, which reads:chanroblesvirtualawlibrary
The failure of petitioners-approving officers to observe all [the] issuances cannot be deemed a mere lapse consistent with the presumption of good faith. Rather, even if the grant of the incentive award were not for a dishonest purpose as they claimed, the patent disregard of the issuances of the President and the directives of the COA amounts to gross negligence, making them liable for the refund thereof.
Manila International Airport Authority v. Commission on Audit:45
The Same is not true as far as the Board of Directors. Their authority under Section 8 of the MIAA charter is not absolute as their exercise thereof is "subject to existing laws, rules and regulations" and they cannot deny knowledge of SSS v. COA and the various issuances of the Executive Department prohibiting the grant of the signing bonus. In fact, they are dutybound to understand and know the law that they are tasked to implement and their unexplained failure to do so barred them from claiming that they were acting in good faith in the performance of their duty.
Rotoras v. COA:46
Meanwhile, officials and officers who disbursed the disallowed amounts are liable to refund: (1) when they patently disregarded existing rules in granting the benefits to be disbursed, amounting to gross negligence; x x x
Department of Public Works and Highways, Region IV-A v. Commission on Audit:
In this case, Cuaresma, as one of the certifying officers of DPWH IV-A, was duty-bound to ensure compliance with the conditions and limitations imposed in PSLMC Resolution No. 4, Series of 2002, in relation to DBM Budget Circular No. 2006-1, before she could issue certification on the availability of funds for the subject CNA Incentive. Unfortunately, she failed in this regard considering the non-observance with the limitation that savings from MOOE shall be the sole source of CNA Incentive. Hence, she must be held liable for the amount of the disallowance.
SECTION 43. Liability for Illegal Expenditures. — Every expenditure or obligation authorized or incurred in violation of the provisions of this Code or of the general and special provisions contained in the annual General or other Appropriations Act shall be void. Every payment made in violation of said provisions shall be illegal and every official or employee authorizing or making such payment, or taking part therein, and every person receiving such payment shall be jointly and severally liable to the Government for the full amount so paid or received.
Any official or employee of the Government knowingly incurring any obligation, or authorizing any expenditure in violation of the provisions herein, or taking part therein, shall be dismissed from the service, after due notice and hearing by the duly authorized appointing official. If the appointing official is other than the President and should he fail to remove such official or employee, the President may exercise the power of removal. (Emphasis supplied)
16.1 The Liability of public officers and other,. persons for audit disallowances/charges shall be determined on, the basis of (a) the nature of - the disallowance/charge; (b) the duties and responsibilities or obligations of officers/employees concerned; '(c) the extent, of their participation in the disallowed/charged transaction; and (d) the amount of damage or loss to the government, thus:The Court has interpreted the above rules as validation of the notion that passive recipients, such as herein payees, shall only be liable to the extent of the amount they unduly received, while, as already discussed, officers who are guilty of bad faith, malice or gross negligence in the disbursement of the disallowed amounts, shall be solidarity liable , therein.52
x x x16.1.5 The payee of an expenditure shall be personally liable for a disallowance where the ground thereof is his failure to submit the required documents, and the Auditor is convinced that the disallowed transaction did not occur or has no basis in fact.
16.2 The liability for audit charges shall be measured by the individual participation and involvement of public officers whose duties require appraisal/assessment/collection of government revenues and receipts in the charged transaction.
16.3 The liability of persons determined to be liable under an ND/NC shall be solidary and the Commission may go against any person liable -without: prejudice to the latter's claim against the rest of the persons liable.
As a supplement to the Madera Rules on Return, the Court now : finds it fitting to clarify that in order to fall under Rule 2c, i.e., amounts genuinely given in consideration of services rendered, the following requisites must concur:chanroblesvirtualawlibraryIt must, thus, be noted that in assessing whether a case falls within the said exception, the foremost consideration should be the legality of the expenditure. This presupposes all the legal conditions for the disbursement were met but for reasons not affecting the genuineness of the payout, such as lack of reportorial requirements or minor missteps in the procedure, the transaction had to be disallowed as a result of some form of irregularity. Only in these kinds of transactions may the payees be excused since the disbursements were legal and given in consideration of actual work. Put differently, the payees of the disbursement truly merited the receipt of the amount, and in the proper course of events, would have received the benefit with no issues at all.(a) the personnel incentive or benefit has proper basis in law but is only disallowed due to irregularities that are merely procedural in nature; andVerily, these refined parameters are meant to prevent the indiscriminate and loose invocation of Rule 2c of Madera Rules on Return which may virtually result in the practical inability of the -government to recover. To stress, Rule 2c as well as. Rule 2d should remain true to their nature as exceptional scenarios; they should not be haphazardly applied as an excuse for non-return, else they effectively override the general rule which, again, is to return disallowed public expenditures.
(b) the personnel incentive or benefit must have a clear, direct, and reasonable connection to the actual performance of the payee-recipient's official work and functions for which the benefit or incentive was intended as further compensation.
With respect to the first requisite above mentioned, Associate Justice Alfredo Benjamin S. Caguioa (Justice Caguioa) - the ponente of Madera - aptly points out that the exception under Rule 2c was not intended to cover compensation not authorized by law or those granted against salary standardization laws. Thus, amounts excused under the said rule should be understood to be limited to disbursements adequately supported by factual and legal basis, but were nonetheless validly disallowed by the COA on account of procedural infirmities. As the esteemed magistrate observes, these may include amounts, such as basic pay, fringe benefits, and other fixed , or yariable forms of compensation permitted under existing laws, which were granted without the due observance of procedural rules and regulations (e.g., matters of form, or inadequate documentation supplied/rectified later on), x x x
x x x
Aside from having proper basis in law, the disallowed incentive or benefit must have a clear, direct, and reasonable connection to the actual performance of the payee-recipient's official work and and functions. Rule 2c after all, excuses ONLY THOSE BENEFITS "genuinely given in consideration of services rendered" in order to be considered as " genuinely given," not only does the benefit or incentive need to have an ostensible, statutory/legal cover, there must be actual work performed and that the benefit or incentive bears a clear, direct, and reasonable relation to the performance of such official work or functions. To hold otherwise would allow incentives or benefits to be excused based on a broad and sweeping association to work that can easily be feigned by unscrupulous public officers and in the process, would severely limit the ability of the government to recover.56
Endnotes:
1Rollo, pp. 208-212; penned by Commission on Audit Chairperson Ma. Gracia M. Pulido Tan and concurred in by Commissioners Heidi L. Mendoza and Jose A. Fabia.
2Id. at 213.
3Id. at 166-167.
4 Amounting to Php69,000,000.00.
5Rollo, pp. 190, 208.
6Id
7Id at 169-171.
8 See also rollo pp. 18-165.
9Id. at 191,
10Id. at 190-193; penned by Commission on Audit Regional Office No. VI, Regional Director IV P. Isidero.
11Id. at 192-193.
12Id. at 212.
13Id. at 210-212.
14Id. at 213.
15Id. at 9-10.
16Id. at 8.
17Id. at 240-247.
18Id. 1, 6.
19Id. at 1.
20Veloso v. Commission on Audit, 672 Phil. 419 (2011); G.R. No. 193677, 06 September 2011 (now CJ) Peralta J. (now CJ) Peralta].
21 Clarificatory Guidelines on the Grant of the Productivity Enhancement Incentive (PEI) to Local Government Personnel for FY 2009, 17 December 2009.
22 DBM Local Budget Circular No. 98, 14 October 2011.
23Rollo, p. 9.
24Id. at p. 211.
25Lumayna v. Commission on Audit, 616 Phil. 92.9 (2009); G.R. No. 185001, 25 September 2009, [Per J. Del Castillo].
26 G.R. No. 244128, 08 September 2020 [Per J. Caguioa].
27 SECTION 38. Liability of Superior Officers. — (1) A public officer shall not be civilly liable for acts done in the performance of his official duties, unless there is a clear showing of bad faith, malice or gross negligence.
x x x
(3) A head of a department or a superior officer shall not be civilly liable for the wrongful acts, omissions of duty, negligence, or misfeasance of his subordinates, unless he has actually authorized by written order the specific act or misconduct complained of.
28 SECTION 39. Liability of Subordinate Officers. — No subordinate officer or employee shall be civilly liable for acts done by him in good faith in the performance of his duties. However, he shall be liable for willful or negligent acts done by him which are contrary to law, morals, public policy and good customs even if he acted under orders or instructions of his superiors.
29 SECTION 43. Liability for Illegal Expenditures. — Every expenditure or obligation authorized or incurred in violation of the provisions of this Code or of the general and special provisions contained in the annual General or other Appropriations Act shall be void. Every payment made in violation of said provisions shall be illegal and every official or employee authorizing or making such payment, or taking part therein, and every person receiving such payment shall be jointly and severally liable to the Government for the full amount so paid or received.
Any official or employee of the Government knowingly incurring any obligation, or authorizing any expenditure in violation of the provisions herein, or taking part therein, shall be dismissed from the service, after due notice and hearing by the duly authorized appointing official. If the appointing official is other than the President and should he fail to remove such official or employee, the President exercise the power of removal.
30 Executive Order No. 292, 25 July 1987.
31Supra at note 26.
32Id. citing Lumayna v. Commission on Audit, G.R. No. 2017, 811 Phil. 344 [Per J. Del Castillo].
33Sambo v. Commission on Audit, G.R. No. 223244, 20 June 2017, 811 Phil. 344 [Per CJ Peralta] citing Casal v. Commission on Audit, G.R. No. 149633, 30 November 2006, 538 Phil. 634 [Per J. Carpio-Morales].
34Constantino v. Sandiganbayan, G.R. Nos. 140656 & 154482, 13 September 2007, 559 Phil. 622 [Per J. Tinga].
35 Separated Concurring Opinion of Senior Associate Justice Perlas-Bernabe, Madera v. Commission on Audit, p. 7.
36Rollo, p. 246.
37Id. at p. 192.
38 G.R. No. 185001,25 September 2009616 Phil. 929 [ Per J. Del Castillo].
39 Supra at note 26.
40 Separate Concurring Opinion of Justice Leonen, Madera v. Commission on Audit, p. 8.
41 G.R. No. 213189, 08 September 2015, 769 Phil. 327 [Per J. Perlas Bernabe]
42 G.R. No 204869, 11 March 2014, 729 Phil. 60 [Per J. Carpio].
43Silang v. Commission on Audit, G.R, No. 213189, 08 September 2015, 769 Phil, 327 [Per J. Perlas-Bernabe].
44 G.R. No. 149633, 30 November 2006, 538 Phil. 634 [Per J. Carpio-Morales].
45 G.R. No. 194710, 14 February 2012, 681 Phil. 644 [Per J. Reyes].
46 G.R. No. 211999, 20 August 2019 [Per J. Leonen].
47 G.R. No. 237987, 19 March 2019 [Per J. J.C. Reyes, Jr.].
48 Supra at note 26.
49 Artic1e 2154-if something is received when there is no right to demand it, and it was unduly delivered through mistake, the obligation to return it arises.
50 Concurring Opinion of Associate Justice Inting, Madera v. Commission on Audit, p. 11.
51 Prescribing the Use of the Rules and Regulations on Settlement of Accounts, COA Circular No. 006-09, 15 September 2009.
52 Supra at note 26.
53Id.
54 According to the 2015 Census, the Province" of Iloilo had a population of 1.9 Million https://www.iloilo.gov.ph/quick-facts, last-accessed on 30 November 2020.
55 G.R. No. 185806, 17 November 2020 (Resolution).
56Id.
57 G.R. Nos. 213323 & 213324, 22 January 2019 [Per J. Leonen].cralawredlibrary