CASE DIGEST: Ocampo v. Commission on Audit

 


MELINDA L. OCAMPO v. COA, GR No. 188716, 2013-06-10

 

Facts:

On 1 March 1996, Ocampo retired from the National Electrification Administration. Ocampo availed of the lump sum payment with a net gratuity of P358,917.01.

Three days thereafter, Ocampo assumed office as Board Member of the ERB. Upon expiration of her term, Ocampo retired under Executive Order No. 172

Ocampo availed of the five year lump sum benefit and the corresponding monthly pension to be paid out for the remainder of her life. This first gratuity lump sum payment based on 60 months or 5 years advance salary was immediately received by Ocampo after her retirement. Likewise, Ocampo began to receive her monthly pension

On 25 August 1998, Ocampo was again appointed, this time as Chairman of ERB with a term of 4 years.

On 15 August 2001, the ERB was abolished and replaced by the Energy Regulatory Commission (ERC)

For the second time, Ocampo sought retirement under Executive Order No. 172.

However, on post-audit of the transaction with Ocampo as payee, State Auditor issued Notice of Suspension (1) suspending payment of the amount of P1,452,613.71 covering Ocampo's second retirement gratuity computed on a pro-rata basis equivalent to only two years, eleven months, and twenty days; and (2) requiring submission by the ERC of "legal basis for [the payment of] retirement gratuity twice under the same law (EO 172)."

Issues:

WHETHER OR NOT PETITIONER IS ENTITLED TO RECEIVE ONLY THE BENEFITS CORRESPONDING TO HER RETIREMENT AS ERB CHAIR, AND THE PERIOD DURING WHICH SHE SERVED AS MEMBER OF THE SAID BOARD SHOULD BE MERELY TACKED IN TO THE PERIOD DURING WHICH SHE SERVED AS SUCH CHAIR.

Ruling:

Textually, the rules on the retirement benefits under Executive Order No. 172, in relation to Republic Act No. 3595, are:

1.       The employee must have completed his term of office, or become incapacitated to discharge the duties of his office, or dies while in the service, or resigns at any time after reaching the age of sixty years but before the expiration of his term of office;

2.       The lump sum is to be paid out according to the employee's number of years of service with the ERB;

3.       The lump sum gratuity to be paid is the employee's salary for one year, not to exceed five years;

4.       The lump sum is based on the employee's last annual salary that he was receiving at the time of retirement, incapacity, death or resignation, as the case may be;

5.       In case of resignation, the employee should have rendered not less than twenty years of service in the government.

The employee shall receive an annuity payable monthly during the residue of his natural life equivalent to the amount of monthly salary he was receiving on the date of retirement, incapacity or resignation.

We disagree with Ocampo that COA should not have audited the first retirement benefit paid to Ocampo as ERB Board Member. COA's plenary authority, consisting of pre and post audit, is enshrined in the Constitution, and as oft observed in jurisprudence. COA validly looked into the government expenditure relating to the first retirement benefit paid to Ocampo because she now claims payment of a second retirement benefit under the same law. Part of the scope of the COA's power, authority and duty is to "promulgate accounting and auditing rules, and regulations including those for the prevention and disallowance of irregular, unnecessary, excessive, extravagant, or unconscionable expenditures, or uses of government funds and properties."

At the outset, it must be clarified that the claim of Ocampo for 2 sets of retirement benefits under Republic Act No. 1568 is not, strictly speaking, a claim for double compensation prohibited under the first paragraph of Section 8, Article IX-B of the Constitution. Claims for double retirement benefits fall under the prohibition against the receipt of double compensation when they are based on exactly the same services and on the same creditable period. This is not, however, the case herein.

In this case, Ocampo is not claiming 2 sets of retirement benefits for one and the same creditable period. Rather, Ocampo is claiming a set of retirement benefits for each of her 2 retirements from the ERB. In other words, each set of retirement benefits claimed by Ocampo is based on distinct creditable periods i.e., one for her term as member of the ERB and another for her term as chairman of the same agency.

What Ocampo is merely claiming, therefore, is that she is entitled to 2 sets of retirement benefits for her 2 retirements from the ERB under Republic Act No. 1568, as amended. Hence, in order to resolve her claim, what is only required is an interpretation of Republic Act No. 1568, as amended.

There is nothing in Republic Act No. 1568 as amended by Republic Act No. 3595 that allows a qualified retiree to therein recover 2 sets of retirement benefits as a consequence of 2 retirements from the same covered agency. As worded, Republic Act No. 1568, as amended, only allows payment of only a single gratuity and a single annuity out of a single compensable retirement from any one of the covered agencies.

In fact, the contingency of multiple retirements from the same covered agency could not have been contemplated by the law. We can confirm this if we take into consideration that Republic Act No. 1568 is a law that, first and foremost, was intended to cover the retirement benefits of the chairmen and members of the COA and of the COMELEC and that it has been the consistent policy of the State, indeed since the 1935 Constitution, to prohibit any appointment of more than one term in the said constitutional bodies. Hence, Republic Act No. 1568, as it was passed and in its present form, cannot be said to have sanctioned the payment of more than one set of retirement benefits to a retiree as a consequence of multiple retirements in one agency.

The mere circumstance that members and chairmen of the ERB may be appointed to serve therein for more than one term (but not for two consecutive terms) does not mean that they would be entitled a set of retirement benefits under Republic Act No. 1568 for each of their completed term. Section 1 of Executive Order No. 172 merely extends to members and chairmen of the ERB similar retirement benefits that retiring members and chairmen of the COA and COMELEC are entitled to under the law. Similar does not mean greater.

Since Republic Act No. 1568, as amended by Republic Act No. 3595 clearly does not justify the payment of more than one gratuity and one annuity to a qualified retiree, Ocampo cannot claim two (2) sets of retirement benefits under the same law.


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