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    Laysa vs. COA

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    asg_jing
    The Commission on Audit (COA) conducted an audit of the Department of Agriculture Regional Office No. V and found irregularities in its transactions relating to equipment purchases, training services, and accounts payable. Based on the audit findings, COA recommended filing administrative cases against involved officers. The petitioner challenged COA's decision. The Supreme Court ruled that COA has constitutional authority to audit government accounts and recommend administrative action. Findings of quasi-judicial agencies like COA are generally accorded respect if supported by evidence, as was the case here. COA did not gravely abuse its discretion in recommending filing of charges.

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    Laysa vs. COA

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    asg_jing
    243 views2 pages
    The Commission on Audit (COA) conducted an audit of the Department of Agriculture Regional Office No. V and found irregularities in its transactions relating to equipment purchases, training services, and accounts payable. Based on the audit findings, COA recommended filing administrative cases against involved officers. The petitioner challenged COA's decision. The Supreme Court ruled that COA has constitutional authority to audit government accounts and recommend administrative action. Findings of quasi-judicial agencies like COA are generally accorded respect if supported by evidence, as was the case here. COA did not gravely abuse its discretion in recommending filing of charges.

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    The Commission on Audit (COA) conducted an audit of the Department of Agriculture Regional Office No. V and found irregularities in its transactions relating to equipment purchases, training services, and accounts payable. Based on the audit findings, COA recommended filing administrative cases against involved officers. The petitioner challenged COA's decision. The Supreme Court ruled that COA has constitutional authority to audit government accounts and recommend administrative action. Findings of quasi-judicial agencies like COA are generally accorded respect if supported by evidence, as was the case here. COA did not gravely abuse its discretion in recommending filing of charges.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    243 views2 pages

    Laysa vs. COA

    Uploaded by

    asg_jing
    The Commission on Audit (COA) conducted an audit of the Department of Agriculture Regional Office No. V and found irregularities in its transactions relating to equipment purchases, training services, and accounts payable. Based on the audit findings, COA recommended filing administrative cases against involved officers. The petitioner challenged COA's decision. The Supreme Court ruled that COA has constitutional authority to audit government accounts and recommend administrative action. Findings of quasi-judicial agencies like COA are generally accorded respect if supported by evidence, as was the case here. COA did not gravely abuse its discretion in recommending filing of charges.

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    © All Rights Reserved
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    Download as docx, pdf, or txt
    of 2

    Laysa vs.

    Commission on Audit
    G.R. No. 128134 | October 18, 2000

    FACTS:
    The Commission on Audit (COA) directed an audit of the
    Fishery Sector Program Fund of the Department of Agriculture
    (DAR) Regional Office No. V, in Pili, Camarines Sur, specifically its
    transactions relating to (a) the purchase of equipment, (b) training
    and catering services, and (c) accounts payable.

    As a result of the audit, the special audit team submitted its


    report (SAO Report), replete with adverse findings and
    observations against the DAR Regional Office No. V. On the basis
    of the aforesaid special audit team’s findings and observations, the
    SAO Report, among others, recommended the refund of the
    disallowed or excessive disbursements and the filing of
    administrative cases against the officers and/or employees involved
    in the said irregularities.

    Petitioner, as Regional Director, appealed the findings of the


    special audit team to the COA en banc; the COA denied the appeal.
    Unable to accept the said decision, petitioner brought a petition
    for certiorari imputing grave abuse of discretion on the part of the
    COA.

    ISSUE:
    Whether or not COA gravely abused its discretion in
    recommending the filing of administrative cases against the officers
    and/or employees involved in irregularities.

    HELD:
    The responsibility for state audit is vested by the
    Constitution in the COA.

    Under the Constitution, the COA “. . . shall have the power,


    authority, and duty to examine, audit, and settle all accounts
    pertaining to the revenue and receipts of, and expenditures or uses
    of funds and property, owned or held in trust by, or pertaining to,
    the Government, or any of its subdivisions, agencies, or
    instrumentalities . . . .” In the exercise of its broad powers,
    particularly its auditing functions, the COA is guided by certain
    principles and state policies to assure that “government funds shall
    be managed, expended, utilized in accordance with law and
    regulations, and safeguarded against loss or wastage . . . with a view
    to ensuring efficiency, economy and effectiveness in the operations
    of government.”
    As can be gleaned from the foregoing provisions of the
    Constitution, verification of whether officials of the agency properly
    discharged their fiscal responsibilities and whether the agency
    complied with internal auditing controls in the collection and/or
    disbursement of government funds, are parts of the functions of the
    COA. Given the COA findings in this case which were
    substantiated by evidence, the COA correctly decided to file the
    charges against the petitioner and the other officers and employees
    involved, leaving the ultimate resolution of the question (whether
    or not their handling of government funds fell short of pertinent
    COA rules and regulations) to be made after trial.

    Findings of quasi-judicial agencies, such as the COA, which


    have acquired expertise because their jurisdiction is confined to
    specific matters are generally accorded not only respect but at times
    even finality if such findings are supported by substantial evidence,
    as in the case at bar.

    In this era of clogged court dockets, the need for specialized


    administrative boards or commissions with special knowledge,
    experience and capability to hear and determine promptly disputes
    on technical questions or essentially factual matters, subject to
    judicial review in case of grave abuse of discretion, is imperative.

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