THE Commission on Audit (COA) affirmed its 2022 ruling that upheld the notice of disallowance against the payment by the Philippine Health Insurance Corp (PhilHealth)-Regional Office 1 of P7,503,861.26 as education assistance allowance to its officials and employees in 2014.
In an en banc resolution, the COA denied the motion for reconsideration filed by PhilHealth RO1 regional vice president Dennis Andre, asserting that the disallowed stipend was valid as it was authorized by the PhilHealth board of directors and the PhilHealth president and chief executive officer.
It likewise challenged the requirement to refund the disallowed amount under the principles of solution indebiti and unjust enrichment, insisting that the payout was anchored on legal grounds.
The COA, however, stood firm that PhilHealth’s fiscal autonomy does not vest it with the authority to ignore standards laid down by compensation laws, including the Salary Standardization Law (RA 6758).
It pointed out that in the 2016 ruling of the Supreme Court in the case of PhilHealth vs. COA, fiscal autonomy was rejected as a justification for the payment of benefits and allowances to PhilHealth’s personnel.
“To be valid, every allowance/benefit payment shall be supported by issuances of the Department of Budget and Management expressly declaring it as non-integrated. Otherwise, succeeding payments of unauthorized allowances or benefits shall be subject to disallowance for being in violation of the general standardization rule,” the Commission said.
Among those held liable for the disallowance were social insurance officer Hazel Lou Cudal, planning officer Raymund Maningding, fiscal controllers Jose Mones, Letecia Ravancho, and Jane Ragos, social insurance officer Laura Basa, division chief Cynthia Santos, administrative officer Marie Donna Antona, human resource management officer Marietta Sosa, and the officials and personnel of PhilHealth RO1.
However, Sosa and Ravancho were excused from solidary liability as the commission noted that their participation in releasing the educational assistance allowance was merely ministerial. They were merely ordered to refund payments received as individuals.
“It must be noted that the officers who certified availability of funds failed to support their appeal with an approved corporate operating budget; they cannot be relieved from solidary liability. Accordingly, Commission on Audit Decision No. 2022-230 dated January 24, 2022 is hereby affirmed with finality,” the COA said.