Slide 1

CONFERENCE/WORKSHOP
on COAs Quasi- Judicial Function

February 7-8, 2017

Old SAADO, COA
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MONEY CLAIM

Definition -
Money claim - a demand for payment of a
sum of money, reimbursement or
compensation arising from law, or contract
due from or owing to a government
agency. (Sec. 4.18, Rule 1, 2009 RRPC)
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MONEY CLAIM
Debt vs. Claim (page 206, SACP)
A debt is a demand for a sum certain. It is
a claim which has been favorably passed
upon by the highest authority to which it
can in law be submitted and has been
declared to be a debt.
A claim, is a debt in embryo, It is a mere
evidence of a debt and must pass through
the process by law before it develops into
what is properly called a debt
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MONEY CLAIM

Historical Background/Legal Basis

1. ACT NO. 3083 - AN ACT DEFINING
THE CONDITIONS UNDER WHICH THE
GOVERNMENT OF THE PHILIPPINE
ISLANDS MAY BE SUED
Approved: March 16, 1923
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MONEY CLAIM

Historical Background/Legal Basis

The immunity of the State from suit, known also
as the doctrine of sovereign immunity or non-
suability of the State, is expressly provided in
Article XVI of the 1987 Constitution, viz:
Section 3. The State may not be sued without its
consent.
The immunity from suit is based on the political
truism that the State, as a sovereign, can do no
wrong.
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MONEY CLAIM

Act 3083
Section 1. Complaint against Government. Subject to the
provisions of this Act, the Government of the Philippine
Islands hereby consents and submits to be sued upon any
moneyed claim involving liability arising from contract,
expressed or implied, which could serve as a basis of civil
action between private parties.

Sec. 2. A person desiring to avail himself of the privilege

herein conferred must show that he has presented his claim
to the Insular Auditor and that the latter did not decide the
same within two months from the date of its presentation.
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MONEY CLAIM

Act 3083
Sec. 7. Execution. No execution shall issue upon any judgment
rendered by any court against the Government of the Philippine
Islands under the provisions of this Act; but a copy thereof duly
certified by the clerk of the Court in which judgment is rendered
shall be transmitted by such clerk to the Governor-General, within
five days after the same becomes final.

Sec. 8. Transmittal of Decision. The Governor-General, at the

commencement of each regular session of the Legislature, shall
transmit to that body for appropriate action all decisions so
received by him, and if said body determine that payment should be
made, it shall appropriate the sum which the Government has been
sentenced to pay, including the same in the appropriations for the
ensuing year.
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MONEY CLAIM

2. Commonwealth Act No. 327.An Act

fixing the time within which the Auditor
General shall render his decisions and
prescribing the manner of appeal
therefrom.
Approved, June 18, 1938.
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MONEY CLAIM

2. Commonwealth Act No. 327

SECTION 1. In all cases involving the settlement of
accounts or claims, other than those of accountable
officers, the Auditor General shall act and decide the
same within sixty days, exclusive of Sundays and
holidays, after their presentation. If said accounts or
claims need reference to other persons, office or
offices, or to a party interested, the period aforesaid
shall be counted from the time the last comment
necessary to a proper decision is received by him.
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MONEY CLAIM
3. Section 26, PD No. 1445. General
jurisdiction.
The authority and powers of the
Commission shall extend to and
comprehend all matters relating to auditing
procedures, systems and controls, xxx;
and settlement of all debts and claims of
any sort due from or owing to the
Government or any of its subdivisions,
agencies and instrumentalities.
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MONEY CLAIM
2009 Revised Rules of Procedure of the Commission on Audit
(RRPC)
RULE II
JURISDICTION AND POWERS OF THE COMMISSION ON AUDIT
Section 1. General jurisdiction. - The Commission on Audit shall
have the power, authority, and duty to examine, audit and settle all
accounts pertaining to the revenues and receipts of, and
expenditures or uses of funds and property, owned or held in trust
by, or pertaining to the Government, xxx

Specifically, such jurisdiction shall extend over but not be limited to
the following cases and matters:
Xxx
2. Money claims due from or owing to any government agency;
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MONEY CLAIM
2009 Revised Rules of Procedure of the Commission on Audit (RRPC)
RULE VIII
ORIGINAL CASES FILED
DIRECTLY WITH THE COMMISSION PROPER
Section 1. Original Jurisdiction. - The Commission Proper shall have
original jurisdiction over: a) money claim against the Government; xxx
Section 2. Money claim. - A money claim against the government shall
be filed directly with the Commission Secretary in accordance with the
following:
Petition. - A claimant for money against the Government, whose claim is
cognizable by the Commission Proper, may file a petition. The party seeking
relief shall be referred to as "Petitioner" and the government agency or
instrumentality against whom a claim is directed shall be referred to as
"Respondent". The petition shall also be assigned a docket number as provided
in these Rules.
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MONEY CLAIM
2009 Revised Rules of Procedure of the Commission
on Audit (RRPC)
RULE IX
PLEADINGS, MODE OF FILING, DOCKETING OF
CASES AND FILING FEE
Section 1. Form of Pleadings. - Pleadings, motions
and other petitions shall contain a caption setting
forth the name and address of the Commission on
Audit, the title of the case, the docket number and the
description of the pleading. They shall be printed or
typewritten double-spaced on legal size bond paper.
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MONEY CLAIM
2009 Revised Rules of Procedure of the Commission on
Audit (RRPC)
RULE X
PROCEEDINGS BEFORE THE COMMISSION PROPER
Section 2. Referral of Money Claim Filed Directly with
the Commission Proper. - Within five (5) days from
receipt of the complete records of the case including the
Answer of the Respondent or other parties in interest, the
Commission Secretary shall refer the said records to the
Director of the appropriate office in the Central/Regional
Office who shall, within fifteen (15) days from receipt
thereof, submit his comment and recommendation to the
Commission Secretary.
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MONEY CLAIM

Definition -
Money claim - a demand for payment of a
sum of money, reimbursement or
compensation arising from law, or contract
due from or owing to a government
agency. (Sec. 4.18, Rule 1, 2009 RRPC)
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MONEY CLAIM

Types -
1. In the exercise of the Original
jurisdiction of COA (Sec. 1, Rule VIII)
2. Court-Adjudicated RTC, Court of
Appeals, Supreme Court
3. Adjudicated by Quasi-Judicial Bodies
Arbitral Awards
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MONEY CLAIM
Authority of Auditor to Settle only liquidated claims-
In Compania General de Tabacos v. French and Unson, 39 Phils 34
(1918), it was ruled that the Auditor xxx has no authority to
adjudicate unliquidated and contested claims against creditors of the
government, since that would be an assumption of judicial power.
The amount of money claim for damages, which cannot be readily
determined from the vouchers, reports, and other means within
reach of accounting officers, but calls for judgment and discretion
upon the measures of damages is not within the competence of the
Auditor General to decide. xxx
Where there is the assertion of the existence of a specific and fixed
indebtedness on the part of the Government, the claim should
therefore be lodged with the Auditor General.[Insurance Co. Of
North America v. Republic, 21 SCRA 40, 1967) (page 214, 215,
SACP Annotated)]
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL.,
INC., v. THE PROVINCE OF BATANGAS,
represented by its Governor, HON.
HERMILANDO I. MANDANAS,
G.R. No. 148106, July 17, 2006
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v.
THE PROVINCE OF BATANGAS,
It was a complaint for sum of money filed
by petitioner Euro-Med Laboratories, Phil.,
Inc. against respondent Province of
Batangas. Respondent filed a motion to
dismiss the complaint on the ground that
the primary jurisdiction over petitioners
money claim was lodged with the
Commission on Audit (COA).
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v. THE PROVINCE OF
BATANGAS,
We rule that it is the COA which does. Therefore, we deny the petition.

The doctrine of primary jurisdiction holds that if a case is such that its
determination requires the expertise, specialized training and knowledge of
an administrative body, relief must first be obtained in an administrative
proceeding before resort to the courts is had even if the matter may well be
within their proper jurisdiction.

This case is one over which the doctrine of primary jurisdiction clearly held
sway for although petitioners collection suit for P487,662.80 was within the
jurisdiction of the RTC, the circumstances surrounding petitioners claim
brought it clearly within the ambit of the COAs jurisdiction.
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v. THE PROVINCE OF
BATANGAS,
First, petitioner was seeking the enforcement of a claim for a certain
amount of money against a local government unit. This brought the case
within the COAs domain to pass upon money claims against the
government or any subdivision thereof under Section 26 of the
Government Auditing Code of the Philippines:

The authority and powers of the Commission [on Audit] shall extend to and
comprehend all matters relating to x x x x the examination, audit, and
settlement of all debts and claims of any sort due from or owing to the
Government or any of its subdivisions, agencies, and instrumentalities. x x
x x.

.
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v. THE PROVINCE
OF BATANGAS,

The scope of the COAs authority to take cognizance of claims is

circumscribed, however, by an unbroken line of cases holding
statutes of similar import to mean only liquidated claims, or
those determined or readily determinable from vouchers,
invoices, and such other papers within reach of accounting
officers. Petitioners claim was for a fixed amount and although
respondent took issue with the accuracy of petitioners summation
of its accountabilities, the amount thereof was readily
determinable from the receipts, invoices and other documents.
Thus, the claim was well within the COAs jurisdiction under the
Government Auditing Code of the Philippines.
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v. THE
PROVINCE OF BATANGAS,

Second, petitioners money claim was founded on a

series of purchases for the medical supplies of
respondents public hospitals.
Both parties agreed that these transactions were
governed by the Local Government Code provisions
on supply and property management and their
implementing rules and regulations promulgated by
the COA pursuant to Section 383 of said Code.
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v.
THE PROVINCE OF BATANGAS,
Petitioners claim therefore involved compliance
with applicable auditing laws and rules on
procurement. Such matters are not within the
usual area of knowledge, experience and
expertise of most judges but within the special
competence of COA auditors and
accountants. Thus, it was but proper, out of
fidelity to the doctrine of primary jurisdiction, for
the RTC to dismiss petitioners complaint.
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MONEY CLAIM
EURO-MED LABORATORIES, PHIL., INC., v. THE
PROVINCE OF BATANGAS,

Petitioner argues, however, that respondent could no longer

question the RTCs jurisdiction over the matter after it had filed
its answer and participated in the subsequent proceedings. To
this, we need only to state that the court may raise the issue of
primary jurisdiction sua sponte and its invocation cannot be
waived by the failure of the parties to argue it as the doctrine
exists for the proper distribution of power between judicial and
administrative bodies and not for the convenience of the
parties.
sua sponte is a decision made by a Judge of his own accord
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MONEY CLAIM
THE PROVINCE OF AKLAN v. JODY KING
CONSTRUCTION AND DEVELOPMENT CORP.,
G.R. Nos. 197592 & 202623, November 27, 2013

Remedial law; Doctrine of primary jurisdiction. The

doctrine of primary jurisdiction holds that if a case is
such that its determination requires the expertise,
specialized training and knowledge of the proper
administrative bodies, relief must first be obtained in
an administrative proceeding before a remedy is
supplied by the courts even if the matter may well be
within their proper jurisdiction.
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MONEY CLAIM
THE PROVINCE OF AKLAN v. JODY KING CONSTRUCTION AND
DEVELOPMENT CORP., G.R. Nos. 197592 & 202623, November
27, 2013

Remedial law; Doctrine of primary jurisdiction.

In such a case, the court in which the claim is sought to be enforced

may suspend the judicial process pending referral of such issues to
the administrative body for its view or, if the parties would not be
unfairly disadvantaged, dismiss the case without prejudice. The
objective of the doctrine of primary jurisdiction is to guide the court in
determining whether it should refrain from exercising its jurisdiction
until after an administrative agency has determined some question
or some aspect of some question arising in the proceeding before
the court.
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MONEY CLAIM
THE PROVINCE OF AKLAN v. JODY KING
CONSTRUCTION AND DEVELOPMENT CORP.,
G.R. Nos. 197592 & 202623, November 27, 2013

Administrative law; The Commission on Audit (COA)

has primary jurisdiction over money claims against
the government. It is the COA and not the RTC which
has primary jurisdiction to pass upon petitioners
money claim against respondent local government
unit. Such jurisdiction may not be waived by the
parties failure to argue the issue nor active
participation in the proceedings.
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MONEY CLAIM
COA Decided Cases-
COA Decision No. 2008-109
The expropriation proceedings was
decided by the RTC and affirmed by the
CA, with modification in amount
Ruling: The CP granted the claim in the
amount as determined by the CA.
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MONEY CLAIM

COA Decision No. 2008-133

Decided by the SC - The judgement award
includes attorneys fees, litigation expenses,
and moral and exemplary damages.
The CP only granted the money claim to
the extent of the value of the lots and the
proceeds of the of palay. All other
expenses/damages awarded by the Court
were excluded in the award.
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MONEY CLAIM

It is not the PNR which should be held

liable in the payment of this amount but
the officials who were negligent for their
failure to file the proper suit. Certainly, the
State, particularly the PNR, cannot be
made to pay for the misdeed and inability
of its officials to settle its legal obligation to
the claimants.
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MONEY CLAIM
. COA Decision No. 2012-241
The CP granted the claim for just compensation,
including interest of 6% from the date of the issuance
of writ of possession by the court xxx up to the finality
of the decision, and 12% from the date of finality until
full payment, based on the ruling of the SC.
The owners loss, of course, is not only his
property but also its income-generating potential.
Thus, when property is taken, full compensation of its
value must immediately be paid to achieve a fair
exchange for property and the potential income lost.
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MONEY CLAIM
The doctrinal ruling that allowed payment of interest
in money claims arising from expropriation cases
was further strengthened in COA Decision No.
2015-160.
But while the award of interest was upheld, the CP
pointed out that the accumulation of interest could
have been prevented if payment was made at an
earlier point in time. Thus, the CP directed the audit
team leader to determine the cause of delay in the
payment of just compensation, and the liability of
the officials who may be found responsible therefor.
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MONEY CLAIM

COA Decision No. 2009-042 Claim of V.C.

Ponce Company, Inc.
MC for actual cost plus interest
Contractor filed a case of Mandamus before the
RTC was able to secure a favorable judgment
The CP noted that the MC should have been
brought before this Commission but [c]onsidering
that the case has been finally adjudicated, this
Commission can only abide by the ruling of the
Court.
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MONEY CLAIM

COA Decision No. 2009-042 Claim of V.C. Ponce

Company, Inc.
However, the CP set aside the imposition of
interest citing jurisprudence to the effect that as a
rule, interest cannot be imposed against the
government. Interestingly, even though the CP said
that it can only abide by the ruling of the Court, it
still required the submission of contracts, vouchers,
ORs and other supporting documents to establish
the veracity of the amount of the judgment award.
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MONEY CLAIM
COA Decision No. 2009-042
Marine Trading Co. vs.The Government of the Phil. Islands, G.R.
No. L-13422, Nov 8, 1918 as citedin CIR vs. Sweeny, G.R. No. L-
12178, August 21, 1959.
It has been established that, as a general rule, in the practice
of the government, that interest is not allowed against it,
whether such claim originate in contract or tort, and whether
they arise in the ordinary business of administration or under
acts of relief, passed by Congress on special application. The
only recognized exceptions are where the government
stipulates to pay interest and where interest is given expressly
by an Act of Congress, either by the name of interest or by that
of damages.
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MONEY CLAIM

COA Decision No. 2013-256:

When later on assailed thru an MR,
basically on the ground that the CP
exceeded its authority when it modified
and altered the RTC decision that had
become final and executory, the CP
denied and ruled in this wise:
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MONEY CLAIM

Anent the first and second grounds, it bears

stressing that in the case of the University of
the Philippines (UP) vs. Hon. Dizon, G.R. No.
171182, August 23, 2012), the Supreme Court
held that the settlement of the monetary claim
against UP was still subject to the primary
jurisdiction of the COA despite the final decision
of the RTC having already validated the claim.
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MONEY CLAIM
On the third ground, it suffices to state that VCPCI has
acquired no vested right on the final and executory decision
of the RTC on money claim against the government over
which COA has the primary jurisdiction (Section 2[1], Article
IX[D]of the 1987 Constitution; Section 26, PD No. 1445)
Supreme Court Administrative Circular No. 10-2000 issued
on October 25, 2000 provides, among others that, it is
settled jurisprudence that upon determination of State
liability, the prosecution, enforcement or satisfaction thereof
must still be pursued in accordance with the rules and
procedures laid down in P.D. No. 1445 xxx.
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MONEY CLAIM
COA Decision No. 2009-093
The Industrial TechnologyDevelopment Institute-DOST (ITDI) pre-
terminated the contract with R.M. Villanueva Construction
(RMVC) due to delays incurred by the latter. ITDI found RMVCs
accomplishment at only 46.71%.
RMVC filed a complaint for sum of money and damages with the
RTC. RTC determined the total uncollected amount due based
on 51.48% completion, plus cost of construction materials
appropriated by ITDI, moral damages, attorneys fees and costs.
When brought before the SC, the SC modified the RTC judgment
- awarding actual damages based on 46.71% completion, cost of
construction materials used by ITDI, and legal interest from the
date of the finality of the decision until full payment.
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MONEY CLAIM

RMVC filed a MC before this Commission based on the SC

decision.
The ATL and the CD, when sought for comment, opined that
there was an error in the computation of actual damages (finding
an overpayment of P324,518.86 after deducting the retention
money).
However, the CP disregarded their comments and granted the
money claim in accordance with the ruling of the SC saying that
this Commission should yield to the authority of the highest court
of the land, and the immutability of final judgment, and as an
exception to the doctrine of exhaustion of administrative
remedies.xxx Being such, this Commission has nothing else to
do, but to abide by the ruling of the High Court.
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MONEY CLAIM

COA Decision No. 2014-420

The CP made its own analysis of the claim
despite the final and executory decision of
the RTC by invoking the primary
jurisdiction of the COA to adjudicate money
claims against the government; Admin
Circular No. 10-2000, as affirmed by a long
line of cases, the latest of which is the
Aklan vs Jody King Devt.Corp
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MONEY CLAIM
COA Decision No. 2015-149
The municipality of Paranaque refused to pay a
claim based on a contract entered into by the
previous administration due t the absence of
competitive bidding. The RTC rendered a
decision granting the claim for 1M damages and
attorneys fees. Paranque still refused to pay
hence, a MC was filed before this Commission.
The claim was granted based on quantum
meruit. The attorneys fee was also granted.
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MONEY CLAIM
COA Decision 2012-123
There are limits to what this Commission may review when
confronted with money claim based on a final and executory judicial
decision. His Commission is bound to respect the final character of
such decision, the merits of the claim having been assessed and
adjudge by the hierarchy of courts. Prudence requires this
Commission to accept the judicial determination of the claim on the
merits against the government instrumentality adjudged as liable.
As a general rule, a final judgment may no longer be altered,
amended or modified, and any attempt on the part of the
responsible entities charged with the execution of a final judgment
to insert, change or add matters not clearly contemplated in the
dispositive portion violates the immutability of judgments.
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MONEY CLAIM
COA Decision 2012-123
The Commission, though, remains mandated to confirm the
veracity of the final judgment on which the money claim is
based before authorizing the disbursement of money to fund the
claim. In doing so, this Commission has to be satisfied as to the
authenticated existence of the final and executory decision, the
precise award to be enforced based on the clear terms of the
judicial decision, and the governmental character of the natural
or juridical persons against whom the claim is sought to been
enforced. Moreover, matters which would bar the issuance by a
regular court of a writ of execution, such as the lapse of the
prescriptive period for enforcing judgments, may also impel this
Commission to similarly bar the money claim.
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MONEY CLAIM
COA Memorandum No. 2016-016 dated July 5, 2016
Subject: General Guidelines in the Adjudication of Money Claims Based on
Final and Executory Judicial Decisions
1. In addition to the requirements under the 2009 RRPC and other rules of
this Commission, the money claim shall be supported with the following
documents:
a) Copy of the final court decision and entry of judgment duly
authenticated by the authorized court officer
b) Authenticated copies of decisions/orders/judgments rendered by the
lower courts, quasi-judicial bodies or tribunals in case the final decision is in
the exercise of appellate jurisdiction of the court whose judgment is being
executed.
c) Comments of the head of the government agency against which the
money claim is being brought by the claimant, including computations for
the amount being claimed.
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MONEY CLAIM

2.The COA officer/employee adjudicating the

claim shall ensure, based on the decision, that:
a) The amount of award is clear, fixed or
determinable.
b) The party against whom the claim is sought to
be enforced is a government entity or the funds
are of a governmental character, and
c) The claim is not barred by prescription or
other similar causes.
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MONEY CLAIM

3. Upon being satisfied of the foregoing, the

COA officer/employee shall determine the
amount of the claim to be granted and draft
the decision for consideration of the CP.

4. The draft decision shall be in accordance

with the final and executory judicial decision
and shall not vary any matter indicated in
the dispositive portion.
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MONEY CLAIM
Construction Industry Arbitration Commission (CIAC) Jurisdiction:
Section 4 of EO 1008, February 4, 1985, CREATING AN ARBITRATION
MACHINERY IN THE CONSTRUCTION INDUSTRY OF THE PHILIPPINES
Sec. 4. Jurisdiction. The CIAC shall have original and exclusive jurisdiction
over disputes arising from, or connected with, contracts entered into by
parties involved in construction in the Philippines, whether the dispute
arises before or after the completion of the contract, or after the
abandonment or breach thereof. These disputes may involve government or
private contracts. For the Board to acquire jurisdiction, the parties to a
dispute must agree to submit the same to voluntary arbitration.
The jurisdiction of the CIAC may include but is not limited to violation of
specifications for materials and workmanship; violation of the terms of
agreement; interpretation and/or application of contractual time and delays;
maintenance and defects; payment, default of employer or contractor and
changes in contract cost.
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MONEY CLAIM
DENR vs. United Planters Consultants, Inc., G.R. No. 212081,
February 23, 2015
The case involves an arbitral award by the Construction Industry
Arbitration Commission (CIAC), the SC held that:
[T]he settlement of respondents money claim is still subject to the
primary jurisdiction of the COA despite finality of the confirmed arbitral
award by the RTC pursuant to the Special ADR rules. Hence, the
respondent has to first seek the approval of the COA for their monetary
claim.
The doctrine of primary jurisdiction does not warrant a court to arrogate
unto itself authority to resolve a controversy the jurisdiction over which
is initially lodged with an administrative body of special competence.
All the proceedings of the court in violation of the doctrine and all
orders and decision rendered thereby are null and void.
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MONEY CLAIM
DENR vs. United Planters Consultants, Inc.,
G.R. No. 212081, February 23, 2015
Since a judgment rendered by a body or tribunal
that has no jurisdiction over the subject matter of
the case is no judgment at all, it cannot be the
source of any obligation. All acts pursuant to it
and all claims emanating from it have no legal
effect and the void judgment can never be final
and any writ of execution based on it is likewise
void. (Aklan vs. Jody King case)
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MONEY CLAIM
Money Claims based on CIAC Final Awards
COA Decision 2009-085
Claim for payment plus 6% interest/annum from
the date of the demand and 12% per annum after
finality of the award was granted. It was affirmed
by the CA.
CP granted the claim, but only to the extent of the
principal. Interest may not be charged as it
incurred due to negligence of government
officers.
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MONEY CLAIM
Money Claims based on CIAC Final Awards
COA Decision No. 2011-095
Claim for escalation cost plus interest was granted by
CIAC but was rendered void by the CA for lack of
approval by the GPBB for the escalation cost. Moreover,
there was no appropriation and CAF. Nonetheless, it
upheld the contractors right to be compensated based on
quantum meruit, the amount to be determined by COA
CP granted only in the amount as determined by the COA
Sr. TAS as reasonable. No interest considering that the
escalation cost was void.
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MONEY CLAIM

COA Decision No. 2013-110

The CP granted the claim including interest
affirmed by the CA, applying the principle,
findings of fact of administrative agencies
and quasi-judicial bodies which have
acquired expertise because their jurisdiction
is confined to specific matters, are generally
accorded not only respect, but finality when
affirmed by the Court of Appeals.
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MONEY CLAIM

The jurisdiction of the COA over money claims

against the government does not include the
power to rule on the constitutionality or validity
of laws. The 1987 Constitution vests the power
of judicial review or the power to declare
unconstitutional a law, treaty, international or
executive agreement, presidential decree,
order, instruction, ordinance, or regulation in
this Court and in all Regional Trial Courts.
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MONEY CLAIM

THANK YOU