Saligumba v COA (117 SCRA 669)

Article IX (D), Section 2.  Section 2. (1) The Commission on Audit shall have the power, authority, and duty to examine, audit, and settle all accounts pertaining to the revenue 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 subdivisions, agencies, or instrumentalities, including government-owned or controlled corporations with original charters, and on a post- audit basis: (a) constitutional bodies, commissions and offices that have been granted fiscal autonomy under this Constitution; (b) autonomous state colleges and universities; (c) other government-owned or controlled corporations and their subsidiaries; and (d) such non-governmental entities receiving subsidy or equity, directly or indirectly, from or through the Government, which are required by law or the granting institution to submit to such audit as a condition of subsidy or equity. However, where the internal control system of the audited agencies is inadequate, the Commission may adopt such measures, including temporary or special pre-audit, as are necessary and appropriate to correct the deficiencies. It shall keep the general accounts of the Government and, for such period as may be provided by law, preserve the vouchers and other supporting papers pertaining thereto. 
(2) The Commission 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. 

Saligumba v COA (117 SCRA 669)

FACTS:

This is a petition for review of the decision rendered by the COA regarding the Administrative case filed by petitioner against Leonardo Estella, Auditing Examiner III of the Auditor’s office of Misamis Occidental. The charge was that the respondent raped Editha Saligumba on several occasions. The COA dropped the administrative complaint due to insufficient evidence. Saligumba petition the court to review such action taken by the COA.



ISSUE:

Whether or not the court may take cognizant of the case.

RULING:

The court dismissed the petition as it held that the power of the Supreme Court to review COA decisions refers to money matters and not to administrative cases involving the discipline of its personnel and even assuming that it does have jurisdiction to review decisions on administrative matters as mentioned above, the court can not do so on factual issues since its power to review is limited to legal issues only.