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Public Officer Compensation Limits

The Supreme Court upholds the Commission on Audit's (COA) decision to disallow monetary benefits granted to members of the Board of Directors (BOD) of the Trade and Investment Development Corporation of the Philippines (TIDCORP). The COA found that Peter B. Favila, who served as an ex-officio member of TIDCORP's BOD as Secretary of the Department of Trade and Industry, improperly received productivity bonuses, bonuses, and other benefits totaling PHP 4,539,835.02. The Court affirmed that Favila's compensation as an ex-officio BOD member is limited by law to a per diem of PHP 500 per meeting. Any additional compensation violates

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Vannyve Baluyut- Navalta
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114 views2 pages

Public Officer Compensation Limits

The Supreme Court upholds the Commission on Audit's (COA) decision to disallow monetary benefits granted to members of the Board of Directors (BOD) of the Trade and Investment Development Corporation of the Philippines (TIDCORP). The COA found that Peter B. Favila, who served as an ex-officio member of TIDCORP's BOD as Secretary of the Department of Trade and Industry, improperly received productivity bonuses, bonuses, and other benefits totaling PHP 4,539,835.02. The Court affirmed that Favila's compensation as an ex-officio BOD member is limited by law to a per diem of PHP 500 per meeting. Any additional compensation violates

Uploaded by

Vannyve Baluyut- Navalta
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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PETER B.

FAVILA VS COMMISSION ON AUDIT


G.R. No. 251824
November 29, 2022

SUBJECT: Local Government Code

NATURE OF THE CASE: Petition for certiorari under rule 64

DOCTRINE: No elective or appointive public officer or employee shall receive additional, double, or
indirect compensation, unless specifically authorized by law.

FACTS: During the period from 2008 to 2010, petitioner Peter B. Favila (Favila), who was then the
Secretary of the Department of Trade and Industry (DTI), served as an ex-officio member of the
Board of Directors (Board/BOD) of the Trade and Investment Development Corporation of the
Philippines (TIDCORP), 4 a government corporate entity created under Presidential Decree No.
(PD) 1080,5 as amended by Republic Act No. (RA) 8494.

TIDCORP's BOD approved eight Board Resolutions approving the grant of productivity
enhancement pay, developmental contribution bonuses, corporate guaranty, grocery subsidy, and
anniversary bonuses to its board members and their alternates. without a prior notice of suspension
COA issued Notice of Disallowance (ND) disallowing various disbursement vouchers and the
corresponding checks in the total amount of PHP 4,539,835.02 pertaining to monetary benefits of
TIDCORP's Board members.

TIDCORP, on behalf of its implicated officers, appealed the disallowance to the Office of the Cluster
Director arguing that Sec. 711 of RA 8494 expressly grants to the Board the exclusive power to fix
the remuneration, emoluments, and fringe benefits of TIDCORP officers and employees. Heir
appeal was denied because Sec. 7 of RA 8494 pertains to the authority of the Board to grant
benefits/bonuses to the officers and employees of TIDCORP, and not to those given to the Board of
Directors, much more to its ex-officio members. Hence a motion for reconsideration was filed but
was denied. Hence this petition.

ISSUE: Whether the COA acted with grave abuse of discretion in denying Favila's petition for review
and affirming the notice of disallowances.

HELD: No. the Court upholds the finding of COA that Favila's right to compensation as member of
the TIDCORP Board in an ex officio capacity is limited only to per diem authorized by law and no
other. In the same vein, there is nothing in the TIDCORP's Charter -PD 1080 that permits the grant
of extra compensation to its BOD and their respective alternates besides a per diem of PHP 500.00
for every board meeting attended. As such, any form of compensation beyond what is provided in
Sec. 1335 of PD 1080 is considered illegal, and in contravention of the constitutional prohibitions
against holding multiple positions in the government and receiving additional or double
compensation.

RULING: The petition for certiorari is dismissed. The decision of the Commission on Audit is hereby
affirmed. Peter B. Favila is held solidarily liable as approving officer and recipient of the disallowed
amount, and is directed to settle the said amount of PHP 4,539,835.02 immediately.

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