- Petitioner
- Jessica M. Chozas
- Respondent
- Commission On Audit
- Citation
- G.R. No. 226319
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- A.B. Reyes, Jr., J.
- Decided
- October 8, 2019
Summary
The Supreme Court En Banc denied consolidated petitions challenging COA's disallowance of P37.8 million Accomplishment Incentive Award granted by Bulacan State University. The Court affirmed COA's constitutional mandate as guardian of public funds and its authority to prevent irregular expenditures. The award was found to lack legal basis under R.A. 8292's Special Trust Fund provisions, which limit expenditures to instruction, research, extension and related programs. Applying ejusdem generis, the Court ruled that 'other programs/projects' must relate to academic functions, not general incentives. The officials' petition was dismissed for being filed 231 days late, violating COA's 6-month appeal period. The Court ordered full restitution under unjust enrichment principles, emphasizing that good faith cannot excuse recipients from returning illegally disbursed public funds. This decision reinforces COA's broad discretionary power in auditing government expenditures and strengthens the constitutional framework preventing wastage of public resources.