JUSTICE MARTIN VILLARAMA, JR.: POWER AND JURISDICTION OF COA

The COA, under the Constitution, is empowered to examine and audit the use of funds by an agency of the national government on a post-audit basis. For this purpose, the Constitution has provided that the COA “shall have exclusive authority, subject to the limitations in this Article, to define the scope of its audit and examination, establish the techniques and methods required therefor, and 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.” As such, CDA’s decisions regarding procurement of equipment for its own use, including computers and its accessories, is subject to the COA’s auditing rules and regulations for the prevention and disallowance of irregular, unnecessary, excessive and extravagant expenditures.  Necessarily, CDA’s preferences regarding brand of its equipment have to conform to the criteria set by the COA rules on what is reasonable price for the items purchased.  

           

We stress anew that it is the general policy of the Court to sustain the decisions of administrative authorities, especially one which is constitutionally-created, not only on the basis of the doctrine of separation of powers but also for their presumed expertise in the laws they are entrusted to enforce. (Sanchez v. Commission on Audit, G.R. No. 127545, April 23, 2008, 552 SCRA 471, 489, citing Cuerdo v. Commission on Audit, No. L-84592, October 27, 1988, 166 SCRA 657, 661 further citing Tagum Doctors Enterprises v. Apsay, No. L-81188, August 30, 1988, 165 SCRA 154, 155-156.)

           

Findings of quasi-judicial agencies, such as the COA, which have acquired expertise because their jurisdiction is confined to specific matters are generally accorded not only respect but at times even finality if such findings are supported by substantial evidence, (Laysa v. Commission on Audit, G.R. No. 128134, October 18, 2000, 343 SCRA 520, 526.) and the decision and order are not tainted with unfairness or arbitrariness that would amount to grave abuse of discretion (Candelario L. Versoza, Jr. vs. Guillermo N. Carague et al., G.R. No. 157838, February 7, 2012, VILLARAMA, JR., J.).