PRA v. Bunag Digest

Facts:
- The Office of the President approved the Corporate Operating Budget of PRA for
calendar year 1992 in the amount of P25, 288, 091. In the same letter, the amount
of P9, 129, 833 representing unjustified/unauthorized allowances, fringe benefits
and other items was disallowed.
-PRA sought to reconsideration from the Office of the President but was denied.
- Due to the reduction of their fund, PRA reduced the compensation of private
respondents and stopped the payment of RATA (Representation and Transportation
Allowance) and other allowances to private respondents.
- Private respondents sought the legal opinion of the DBM on the disallowance. DBM
opined that "the total monthly compensation and allowances sought have NO
LEGAL BASIS".
-Private respondents elevated the case to the Office of the President and OP
reversed the ruling of DBM stating the PRA needs no prior approval or authority
from the DMB with respect to the compensation scheme of PRA and its grants of
allowance to its employees.
- Petitioner PRA filed a petition for review with the Court of Appeals. However, the
Court of Appeals upheld the decision of the Office of the President.
- PRA now argues that these allowances and benefits were not authorized or
approved by the DBM, contrary to EO 1037 in relation to PD 985 and PD 1597 (See
notes for regarding these PDs and RA). PRA explains that prior to RA 6758,
disbursements of compensation, allowances and other benefits to PRA employees
are subject to the review of DBM. PRa reasoned that the transitory provisions of RA
6758 which authorize the continued grant of allowances and benefits received by
incumbents as of the effectivity of said law is not applicable as the law could not
have contemplated the continued disbursement of unauthorized allowances and
benefits.
-Private respondents argue that PRA has the requisite power and authority to
impose and implement a compensation scheme for its employees without need of
prior approval or authority of the DBM.
ISSUE: WON whether disbursements made by PRA of compensation, allowances,

and other benefits of its employees prior to the effectivity of RA 6758 or the
Compensation and Position Classification Act of 1989 is subject to the review of the
Department of Budget and Management. YES, however, the review power of DBM
is limited. The role of DBM supervisorial in nature, its main duty being to ascertain that
the proposed compensation, benefits and other incentives to be given to PRA officials and
employees adhere to the policies and guidelines issued in accordance with applicable
laws.
WHEREFORE, the decision of the Court of Appeals in CA-G.R. SP No. 47818
is MODIFIED as follows:
(a) Compensation and allowances granted to private respondents prior to the effectivity of
R.A. No. 6758 without the authority or approval of the Department of Budget and
Management are unauthorized and disallowed; and
(b) Particular items of disallowance of the Corporate Operating Budget of PRA for
Calendar Year 1992 representing various allowances and benefits in theamount of
P1,324,822.00 based solely on particular provisions of DBM-CCC No. 10, in view of the
nullity of DBM-CCC No. 10, are void.
HELD - The Court visited its prior ruling in the case of Intia v. Commission on Audit
stating that "The DBM's function is merely to ensure that the action taken by the
Board of Director complies with the requirements of law..."
-Court agrees that the Board of Director of Petitioner PRA has the power to establish
and fix a compensation and benefits scheme for its employees, the same is subject
to the review of DBM. However, in view of the express powers granted to PRA under
its charter, the extent of the review authority of DBM is LIMITED. As stated in Intia,
the task of DBM is to simply review the compensation and benefits plan of the
government agency or entity concerned and determine if the same complies with
the prescribed policies and guidelines issued in this regard. "The role of DBM is
supervisional in nature" its main duty being to ascertain that the proposed
compensation, benefits, and other incentives adhere to the policies and guidelines
issued in accordance with applicable laws.
- With regard to the argument of the respondents that they are still entitled to
receive compensation and allowances as the transitory provisions of RA 6758
states, the Court held that the foregoing transitory provisions do not contemplate a
situation where the grant of unauthorized or irregular compensation and benefits
would be continued or subsequently authorized by the passage of the law.
Case:
Intia vs. Commission on Audit
It should be emphasized that the review by the DBM of any PPC resolution affecting the
compensation structure of its personnel should not be interpreted to mean that the DBM can
dictate upon the PPC Board of Directors and deprive the latter of its discretion on the matter.
Rather, the DBM's function is merely to ensure that the action taken by the Board of Directors
complies with the requirements of the law, specifically that PPC's compensation system
"conforms as closely as possible with that provided for under R.A. No. 6758."
Notes:
RA 6758 - Declared the policy of the national government is to provide "equal pay
for substantially equal work and to base differences in pay upon substantive
differences in duties and responsibilities and qualification requirements of the
positions."
PD 985 - Provided for standardized compensation of government employees and

officials including those in GOCCs.
PD 1597 - Enacted prescribing the duties to be followed by the agencies and offices
exempt from coverage of the rules and regulation of the Office of Compensation and
Position Classification.

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Facts:

ISSUE: WON whether disbursements made by PRA of compensation, allowances,

PD 985 - Provided for standardized compensation of government employees and

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