Digest.ph

This case involves a petition for certiorari filed by the National Transmission Corporation (TransCo) against the Commission on Audit (COA) and COA Chairperson Michael G. Aguinaldo. The case revolves around the disallowance of separation benefits granted to a former TransCo employee, Benjamin B. Miranda. The COA ruled that Miranda was not entitled to the separation benefits because his appointment was not approved or attested to by the Civil Service Commission (CSC). TransCo argues that Miranda should be entitled to the benefits based on his functions and the nature of his employment. The court ultimately upholds the COA's decision, stating that all employees of TransCo are entitled to separation benefits, but casual or contractual employees must have their appointments approved by the CSC. The court also abandons the precedent set in a previous case, Lopez v. MWSS, which allowed for the award of separation benefits to employees despite the lack of CSC approval. However, the court exempts TransCo and Miranda from refunding the disallowed amount, as they acted in good faith.

The court affirms that all employees of TransCo are entitled to separation benefits, but casual or contractual employees must have their appointments approved or attested to by the Civil Service Commission (CSC). The court also abandons the precedent set in Lopez v. MWSS, which allowed for the award of separation benefits to employees despite the lack of CSC approval. Good faith may exempt passive recipients of disallowed benefits from refunding the amount.