Buscaino v. Commission on Audit

Summary

This case involved COA's audit disallowances against PUP's Director of Fiscal Management Services Odelon Buscaino totaling P1,527,176.40 for alleged overpricing and procedural violations in government procurement. The Supreme Court reversed COA's decision, finding grave abuse of discretion because COA failed to provide documentary evidence supporting overpricing claims despite petitioner's requests, violating due process rights. The Court emphasized that government officials performing ministerial duties cannot be held liable for decisions made by their superiors within proper authority, and that audit disallowances must be supported by sufficient evidence rather than mere allegations. This decision reinforced procedural due process requirements in administrative proceedings and clarified the scope of liability for government employees in audit cases, establishing that transparency and access to supporting documents are essential for valid audit disallowances.