Case Digest
Case Digest
Case Digest
Tantuico
G.R. No. L-47051
July 29, 1988
Facts:
petitioners, with respect to their Coconut Consumers Stabilization Fund levy collections
As a result of the initial findings of the Performance Audit Office with respect only
to the petitioners, respondent Acting COA Chairman directed the Chairman, the
Administrator, and the Military Supervisor of PCA and the Manager of the Coconut
of petition) to collect the short levies and overpaid subsidies, and to apply subsidy
claims to the settlement of short levies should the petitioners fail to remit the amount
due.
Issues:
Whether or not the respondent COA Chairman may disregard the PCA rules and
Ruling:
In the case at bar, the petitioners have failed to show that acts were done with
Section 2 (1) of Article IX-D of the Constitution provides that "The Commission on
Audit shall have the power, authority and duty to examine, audit, and settle all accounts
pertaining to the revenues and receipts of, and expenditures or uses of funds and
property, owned or held in trust by or pertaining to, the Government, or any of its
corporation with original charters, and on a post-audit basis. ... (d) such non-
the Government which are required by law or the granting institution to submit to such
audit as a condition of subsidy or equity." The Constitution formally embodies the long
established rule that private entities who handle government funds or subsidies in trust
In cases involving specialized disputes, the trend has been to refer the
Court in Pambujan Sur United Mine Workers v. Samar Mining Co., Inc. (94 Phil.
932,941), held that under the sense-making and expeditious doctrine of primary
jurisdiction ... the courts cannot or will not determine a controversy involving a
comply with the Purposes of the regulatory statute administered." Recently, this
Court specaking thru Mr. Chief Justice Claudio Teehankee said that "In this era
commissions with the special knowledge, experience and capability to hear and
subject to judicial review in case of grave abuse of discretion, has become well-
nigh indispensable." The court reminds us that the legal presumption is that