Magante et al. vs. Commission on Audit et al.

The COA's jurisdiction over money claims arising from a final and executory judgment is limited to the execution of that judgment; it cannot take cognizance of factual and legal issues that have been raised or could have been raised before the court or tribunal which previously had jurisdiction over the same, nor can it grant claims beyond what is in the ruling. The COA does not commit grave abuse of discretion when it refrains from ruling on claims, such as salary differentials for rehired employees and attorney's or agency fees, that were not adjudicated in the final judgment and would require presentation of evidence in a proper forum.

Republic Act No. 9136, the Electric Power Industry Reform Act (EPIRA), was enacted on June 26, 2001 to reform the electric power industry, including the privatization of the assets and liabilities of the National Power Corporation (NPC). Pursuant to EPIRA, the National Power Board (NPB) was created, consisting of seven Cabinet Secretaries and two heads of agencies. The law also created the Power Sector Assets and Liabilities Management Corporation (PSALM) to manage the privatization of NPC's assets and to assume NPC's liabilities. The dispute concerns the separation benefits of NPC employees terminated pursuant to NPB resolutions that were later declared void by the Supreme Court.

On June 26, 2001, Republic Act No. 9136, the Electric Power Industry Reform Act (EPIRA), was enacted to reform the electric power industry, including the privatization of the assets and liabilities of the National Power Corporation (NPC). Pursuant to Section 63 of the EPIRA, the National Power Board (NPB) issued NPB Resolution No. 2002-124 on November 18, 2002, providing guidelines for the separation program of NPC personnel, who were to be terminated on January 31, 2003. On the same date, NPB issued Resolution No. 2002-125 constituting a transition team to manage the separation program.

Members of the NPC Drivers and Mechanics Association (DAMA), NPC Employees and Workers Union (NEWU)-Northern Luzon Regional Center, and other concerned employees filed a Petition for Injunction before the Supreme Court to enjoin the implementation of the resolutions, contending that they were not passed by a majority of the NPB members since only three out of nine members were present and qualified to vote. The Supreme Court did not issue a temporary restraining order, and NPC proceeded with the termination beginning January 31, 2003.

In a Decision dated September 26, 2006, the Supreme Court nullified NPB Resolution Nos. 2002-124 and 2002-125, holding that the resolutions were not properly enacted due to the failure of four specifically identified Cabinet Secretaries to personally approve and sign the resolutions. The decision was silent as to the effect of the nullity on the terminated employees. In a Resolution dated September 17, 2008, the Court clarified that the logical and necessary consequence of the declaration of nullity was the illegality of the dismissal of the employees, entitling them to reinstatement or separation pay in lieu thereof, backwages, wage adjustments, and all other benefits accruing from January 31, 2003, less the amount of separation benefits previously received.

The 2006 Decision became final and executory on October 10, 2008. The Court subsequently granted a motion for execution and directed the NPB and NPC to prepare a verified list of terminated employees and pay the amounts due, including 12% legal interest. Citing willful failure to comply, the terminated employees moved for garnishment and/or levy of NPC assets, including PSALM's assets. PSALM filed a Manifestation stressing that it was not bound by the judgment since it was not a party, and that EPIRA does not allow garnishment of its assets. The NPC finally submitted the list of 9,272 terminated employees on October 20, 2014. In its June 30, 2014 Resolution, the Court rejected PSALM's contention and held it directly liable for the obligation, explaining that this was part of the obligations PSALM took over from NPC when EPIRA took effect, but pointed out that petitioners should file their money claims before the COA.

In the assailed Decision No. 2019-416 dated September 23, 2019, the COA partially granted the Petitions for Money Claim, holding that the employees' entitlement to monetary awards had been sufficiently established by the Court. The COA held that those who had been rehired by NPC, absorbed by PSALM or Transco, or transferred to another government agency, were not entitled to backwages, as these would amount to unjust enrichment. The COA also refrained from ruling on the rehired employees' claim for salary differentials, and held that claims for attorney's fees of Atty. Napoleon Galit and the 5% agency fee for DAMA, NEWU, and NECU were not within the purview of the Commission. The COA upheld the Court's imposition of legal interest at 12% per annum from October 10, 2008 to June 30, 2013, and 6% per annum from July 1, 2013 onwards.

• Procedural Infirmities: Petitioners in G.R. No. 253395 filed their Petition out of time, having received the assailed Decision on September 24, 2019, filed a motion for reconsideration on October 14, 2019, and filed the Petition only on September 30, 2020, beyond the remaining 11-day balance of the 30-day period under Rule 64, Section 3.

• Salary Differentials: Petitioners argued that the COA committed grave abuse of discretion in failing to grant the more than 7,000 rehired NPC workers their salary differentials, which they defined as "the amount of benefit previously enjoyed by the re-hired group of workers – but were sadly cut-off, removed, or deducted from their basic pay at the time they were re-hired."

• Class Suit Jurisdiction: Petitioners argued that the COA failed to recognize that the petition before it was a class suit and that it had acquired jurisdiction over all the 9,272 claimants, and that the COA failed to accord recognition to the petitioners as the same parties who filed the Petition in G.R. No. 156208.

• Attorney's and Agency Fees: Petitioners argued that the COA failed to grant the class-suit petitioners' and their lawyers' attorney's fees for Atty. Napoleon Galit, who filed the class-suit petition and shouldered the docket fee, and failed to accord recognition of the agency fee agreed by NPC Unions, DAMA, NEWU, and NECU.

• Application of Void Resolutions: Petitioners argued that the COA failed to apply the principle and consequences of the declared void NPB Resolutions, which entitled them to restoration of their full enjoyment of salaries that were reduced when they were rehired.

• Source of Funds: PSALM argued that the COA is authorized to determine the source of funds for the payment of the judgment award, and that said award must be sourced solely from the proceeds from the sale or privatization of NPC's assets, as mandated by EPIRA.

• Availability of Funds: PSALM contended that legal interest may only be paid subject to the availability of funds, citing COA Decision No. 2017-110 which stated that legal interest cannot be awarded in the absence of funds duly appropriated for such purpose.

• Documentation and Validation: PSALM argued that each money claim should be carefully examined and validated on a case-to-case basis, subject to submission of complete and proper documentation consistent with Section 4 of Presidential Decree No. 1445, and that the status of employment relations should be confirmed by the Civil Service Commission.

• Specification of Benefits: PSALM pointed out that the COA failed to specify the "other monetary benefits" to be included in the computation of backwages, and the proper person or entity to direct the release of said funds.

• COA's Position on Source of Funds: The COA, through the Office of the Solicitor General, argued that it is not within the Commission's functions to determine the source of funds for the payment of money claims, as its jurisdiction under Article IX-D, Section 2(1) of the Constitution is for the "examination, audit, and settlement" of the use and disbursement of public funds, and that it is for Congress, which has the power to appropriate public funds, to determine the source of funds.

• COA's Position on Legal Interest: The COA averred that the payment of legal interest has already been mandated by the Court in its November 21, 2017 Resolution, which is "imperative without qualification" and cannot be made to depend on availability of funds.

• Timeliness of Petition (G.R. No. 253395): Whether the Petition in G.R. No. 253395 was filed out of time under Rule 64, Section 3 of the Rules of Court.

• Salary Differentials for Rehired Employees: Whether the COA committed grave abuse of discretion in refraining from ruling on the rehired employees' claim for salary differentials.

• Attorney's Fees and Agency Fees: Whether the COA committed grave abuse of discretion in holding that claims for attorney's fees of Atty. Galit and agency fees of the unions were not within its jurisdiction to grant.

• Source of Funds for Judgment Obligation: Whether the COA has jurisdiction to determine the source of funds for the payment of the judgment obligation.

• Exclusivity of NPC Asset Sale Proceeds: Whether the amount to be paid under the judgment obligation should be exclusively from the sale of NPC assets.

• Availability of Funds for Legal Interest: Whether the payment of legal interest should be subject to the availability of funds.

• Specification of Backwages Benefits: Whether the COA failed to specify the benefits to be included in the computation of backwages.

• Timeliness of Petition (G.R. No. 253395): No. The Petition was filed out of time, but the Court exercised its discretion to relax technical rules of procedure in favor of substantial justice, as the immediate dismissal would prejudice thousands of rehired employees and their counsels.

• Salary Differentials for Rehired Employees: No. The COA did not commit grave abuse of discretion when it refrained from ruling on the claim for salary differentials, as the claim was not within the purview of the COA to decide and would require the presentation of evidence to establish entitlement.

• Attorney's Fees and Agency Fees: No. The COA correctly held that it had no power to determine, let alone grant, claims for attorney's fees and agency fees that were not subject of the Court's issuances in G.R. No. 156208, as its mandate extends only to the execution of the decision that granted such claim.

• Source of Funds for Judgment Obligation: No. The COA has no authority to determine the source of funds from which the NPC's obligation to the terminated employees may be taken, as its powers are limited to "examination, audit, and settlement" under Article IX-D, Section 2(1) of the Constitution, and the power of appropriation is vested in the Legislature.

• Exclusivity of NPC Asset Sale Proceeds: No. Neither the EPIRA, its IRR, nor the Court's issuances support the argument that the judgment obligation should be paid exclusively from the sale of NPC assets, as the use of "may" in the Court's ruling dispels this contention.

• Availability of Funds for Legal Interest: No. The award of legal interest is a "natural consequence of a final judgment" and is not defeated notwithstanding the fact that the parties were at variance in the computation of what is due under the judgment; the payment of legal interest is not optional, nor can it be made to depend on the availability of funds.

• Specification of Backwages Benefits: No. The Court has already determined the benefits to which the terminated claimants are entitled, and jurisprudence provides guidance on how to compute the award for backwages, including all salary increases and benefits granted under the law and other government issuances.

• Timeliness of Petition (G.R. No. 253395): The Court examined the nature of the petition, noting that although denominated as one for certiorari under Rule 65, the allegations revealed that it was an appeal of the COA's Decision, which must be read in conjunction with Rule 64. Under Section 3 of Rule 64, the petition shall be filed within 30 days from notice of the judgment. Petitioners received the assailed Decision on September 24, 2019, and had until October 24, 2019 to file. The period was interrupted by a motion for reconsideration filed on October 14, 2019, leaving a balance of 11 days. The motion was denied on September 11, 2020, giving them until September 22, 2020 to file, but the Petition was filed only on September 30, 2020. Nonetheless, the Court has the discretion to relax technical rules of procedure in favor of substantial justice, and the immediate dismissal would prejudice thousands of rehired employees and their counsels.

• Salary Differentials for Rehired Employees: The Court revisited its November 21, 2017 Resolution, which clarified that rehired or absorbed employees are not entitled to backwages, as this would violate constitutional prohibitions against double office-holding and double compensation, and would amount to unjust enrichment. The Court explained that under Section 63 of the EPIRA, those who will be absorbed or rehired by any government-owned successor company will be considered as new employees who start their service anew. Thus, they cannot claim the benefits of their previous positions unless they can show that the position to which they were hired held the exact same salary grade, remuneration, and benefits. The Court held that the claim for salary differentials was not within the purview of the COA to decide in the assailed Decision, and would require the presentation of evidence to establish whether petitioners are indeed entitled to the same.

• Attorney's Fees and Agency Fees: The Court distinguished between two main types of money claims which the COA may be confronted with: (1) money claims originally filed with the COA, which are limited to liquidated claims; and (2) money claims which arise from a final and executory judgment of a court or arbitral body, over which the COA's power for audit review is limited. The Court cited the principle that when a court or tribunal having jurisdiction over a money claim against the government renders judgment and the same becomes final and executory, the COA cannot alter the same and disregard the principle of immutability of final judgments. Since the claim for attorney's fees by Atty. Galit was not subject of the Court's issuances in G.R. No. 156208, the COA correctly held that it had no power to determine, let alone grant, such claim. Similarly, the claim for agency fee by the claimant NPC unions was not subject of the Decision in G.R. No. 156208, and an agency fee is an obligation between the union and non-union members recognized under the law, the collection of which is recognized by Article 259(e) of the Labor Code. The Court cited Peninsula Employees Union vs. Esquivel to explain that the legal basis of the union's right to agency fees is quasi-contractual, deriving from the principle that non-union employees may not unjustly enrich themselves by benefiting from employment conditions negotiated by the bargaining union.

• Source of Funds for Judgment Obligation: The Court agreed with the COA that it has no authority to determine the source of funds from which the NPC's obligation may be taken. The powers of the COA are defined by Article IX-D, Section 2(1) of the Constitution, which grants it 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. This is further specified in Section 26 of Presidential Decree No. 1445. The Court held that the COA's powers over debts and claims from or owing the government is limited to its "examination, audit, and settlement," and it is not the appropriate entity to determine the funds from which the settlement may be sourced. Under the Constitution, the power of appropriation is vested in the Legislature, and budget execution comes under the domain of the Executive branch.

• Exclusivity of NPC Asset Sale Proceeds: The Court rejected PSALM's contention that the amount to be paid under the judgment obligation should be exclusively from the sale of NPC assets. The Court cited its previous ruling that PSALM's assets may be subject of the execution of the case, and that under the EPIRA, PSALM shall assume all of NPC's existing generation assets, liabilities, IPP contracts, real estate, and other disposable assets. The use of "may" dispels PSALM's contention that only such assets may be used to satisfy the judgment. The Court also noted that Section 49 of EPIRA states that PSALM takes ownership of NPC's "generation assets, liabilities, IPP contracts, real estate and all other disposable assets," and Section 50 authorizes PSALM to manage the orderly sale, disposition, and privatization of these assets with the objective of liquidating all NPC financial obligations.

• Availability of Funds for Legal Interest: The Court reiterated that the award of legal interest is a "natural consequence of a final judgment and is not defeated notwithstanding the fact that the parties were at variance in the computation of what is [due] under the judgment." The Court recalled that in G.R. No. 156208, it ruled that legal interest shall be computed at 12% per annum from October 8, 2008 until June 30, 2013, and 6% per annum from July 1, 2013 onwards. Thus, the payment of legal interest is not optional, nor can it be made to depend on the availability of funds.

• Specification of Backwages Benefits: The Court held that it has already painstakingly laid down the benefits to which the terminated claimants are entitled: (a) separation pay in lieu of reinstatement; (b) backwages; (c) wage adjustments; minus any separation pay already received under the restructuring plan. The Court cited Dumapis vs. Lepanto Consolidated Mining Co. for the uniform rule that the award of backwages and/or separation pay due to illegally dismissed employees shall include all salary increases and benefits granted under the law and other government issuances, Collective Bargaining Agreements, employment contracts, established company policies and practices, and analogous sources which the employees would have been entitled to had they not been illegally dismissed. The Court also directed the NPC to turn over to the COA all relevant documents, including employment records, of the judgment claimants, for verification of claims and proper computation of their entitlement, as claims against government funds shall be supported with complete documentation under the Government Auditing Code.

• COA's Limited Jurisdiction Over Money Claims Arising from Final Judgments — The COA's power of audit review over money claims arising from a final and executory judgment of a court or arbitral body is limited. The COA cannot take cognizance of factual and legal issues that have been raised or could have been raised before the court or tribunal which previously had jurisdiction over the same. When a court or tribunal having jurisdiction over a money claim against the government renders judgment and the same becomes final and executory, the COA cannot alter the same and disregard the principle of immutability of final judgments. The COA's mandate extends only to the execution of the decision that granted such claim, and it cannot grant any claim beyond what is in the ruling.

• Rehired Employees Not Entitled to Backwages — Employees who were subsequently rehired by the NPC, absorbed by PSALM or Transco, or transferred or employed by other government agencies, are not entitled to backwages. To award full backwages to those who remained employed as a direct result of the 2003 reorganization amounts to unjust enrichment and damage to the government, and violates the constitutional prohibitions against double office-holding and double compensation in the civil service under Sections 7 and 8, Article IX-B of the Constitution.

• Rehired Employees as New Employees — Under Section 63 of the EPIRA, those who avail of the separation privileges shall start their government service anew if absorbed by any government-owned successor company. Their re-employment is not a continuation of their previous service with NPC, and they cannot claim the benefits of their previous positions. Unless they can show that the position to which they were hired held the exact same salary grade, remuneration, and benefits as to merit the same salary they had prior to reorganization, they are entitled only to the compensation of the new position.

• Agency Fee as Quasi-Contractual Obligation — The legal basis of the union's right to agency fees is neither contractual nor statutory, but quasi-contractual, deriving from the established principle that non-union employees may not unjustly enrich themselves by benefiting from employment conditions negotiated by the bargaining union. The collection of agency fees in an amount equivalent to union dues and fees, from employees who are not union members, is recognized by Article 259(e) of the Labor Code.

• COA's Power Limited to Examination, Audit, and Settlement — The COA's powers over debts and claims from or owing the government is limited to its "examination, audit, and settlement" under Article IX-D, Section 2(1) of the Constitution. The COA is not the appropriate entity to determine the funds from which the settlement may be sourced, as the power of appropriation is vested in the Legislature, and budget execution comes under the domain of the Executive branch.

• Legal Interest as Natural Consequence of Final Judgment — The award of legal interest is a "natural consequence of a final judgment and is not defeated notwithstanding the fact that the parties were at variance in the computation of what is [due] under the judgment." The payment of legal interest is not optional, nor can it be made to depend on the availability of funds.

• Inclusions in Backwages Computation — The award of backwages and/or separation pay due to illegally dismissed employees shall include all salary increases and benefits granted under the law and other government issuances, Collective Bargaining Agreements, employment contracts, established company policies and practices, and analogous sources which the employees would have been entitled to had they not been illegally dismissed. Salary increases and other benefits which are contingent or dependent on variables such as an employee's merit increase based on performance or longevity or the company's financial status shall not be included in the award.

• "Accordingly, when a court or tribunal having jurisdiction over a money claim against the government renders judgment and the same becomes final and executory, the COA cannot alter the same and disregard the principle of immutability of final judgments." — This passage articulates the controlling doctrine on the COA's limited jurisdiction over money claims arising from final judgments, which is central to the Court's ruling that the COA correctly refrained from granting claims beyond the judgment in G.R. No. 156208.

• "The recognized collective bargaining union which successfully negotiated the CBA with the employer is given the right to collect a reasonable fee called 'agency fee' from non-union members who are employees of the appropriate bargaining unit, in an amount equivalent to the dues and other fees paid by union members, in case they accept the benefits under the CBA. While the collection of agency fees is recognized by Article 259 (formerly Article 248) of the Labor Code, as amended, the legal basis of the union's right to agency fees is neither contractual nor statutory, but quasi-contractual, deriving from the established principle that non-union employees may not unjustly enrich themselves by benefiting from employment conditions negotiated by the bargaining union." — This passage, quoted from Peninsula Employees Union v. Esquivel, defines the legal basis of agency fees and supports the Court's holding that such claims are beyond the COA's jurisdiction.

• "Verily, the Court now ordains the uniform rule that the award of backwages and/or separation pay due to illegally dismissed employees shall include all salary increases and benefits granted under the law and other government issuances, Collective Bargaining Agreements, employment contracts, established company policies and practices, and analogous sources which the employees would have been entitled to had they not been illegally dismissed. On the other hand, salary increases and other benefits which are contingent or dependent on variables such as an employee's merit increase based on performance or longevity or the company's financial status shall not be included in the award." — This passage, quoted from Dumapis v. Lepanto Consolidated Mining Co., provides the uniform rule for computing backwages and addresses PSALM's argument that the COA failed to specify the benefits to be included in the computation.

• "We reiterate Our finding in Our Resolution dated June 30, 2014 that, upon the NPC's privatization, PSALM assumed all of its liabilities, including the separation benefits due to the petitioners. That PSALM assumed the NPC's liability to pay these separation benefits is clear based on the following reasons: (1) The liability was already existing at the time of the EPIRA's effectivity and was transferred from NPC to PSALM by virtue of Section 49 of the law; (2) It is a 'Transferred Obligation' as defined under the Deed of Transfer; and (3) Under the EPIRA, PSALM is duty-bound to settle the subject liability." — This passage establishes with finality PSALM's direct liability for the judgment obligation, rejecting PSALM's arguments in G.R. No. 253967.

• NPC Drivers and Mechanics Association vs. National Power Corp., 534 Phil. 233 (2006) — Controlling precedent that declared NPB Resolution Nos. 2002-124 and 2002-125 void for failure of the four specifically identified Cabinet Secretaries to personally approve and sign the resolutions.

• NPC Drivers and Mechanics Association vs. National Power Corp., 587 Phil. 189 (2008) — Followed; clarified that the nullity of the NPB resolutions resulted in the illegal dismissal of the employees, entitling them to reinstatement or separation pay, backwages, wage adjustments, and other benefits.

• NPC Drivers and Mechanics Association vs. National Power Corp., 737 Phil. 210 (2014) — Followed; held PSALM directly liable for the judgment obligation as part of the liabilities it took over from NPC under EPIRA.

• NPC Drivers and Mechanics Association vs. National Power Corp., 821 Phil. 62 (2017) — Controlling precedent; clarified the entitlements of separated employees, including the rule that rehired or absorbed employees are not entitled to backwages, and specified the guidelines for computing separation pay and backwages.

• Taisei Shimizu Joint Venture vs. Commission on Audit, 873 Phil. 323 (2020) — Cited for the distinction between the two main types of money claims which the COA may be confronted with, and the limited power of the COA for audit review over money claims arising from a final and executory judgment.

• Spouses Ting vs. Commission on Audit, 908 Phil. 772 (2021) — Cited for the principle that when a court or tribunal having jurisdiction over a money claim against the government renders judgment and the same becomes final and executory, the COA cannot alter the same and disregard the principle of immutability of final judgments.

• Peninsula Employees Union vs. Esquivel, 801 Phil. 667 (2016) — Cited to explain the quasi-contractual basis of the union's right to agency fees.

• Campol vs. Balao-As — Distinguished; the Court revisited its ruling in Campol, agreeing with Justice Antonio T. Carpio's opinion that the award of full backwages to an illegally dismissed civil service employee who was subsequently employed in another government agency violates constitutional prohibitions against double office-holding and double compensation.

• Bustamante vs. National Labor Relations Commission and Equitable Banking Corporation vs. Sadac — Cited for the prevailing doctrine in the award of backwages in the private sector, applied to petitioners who were neither rehired nor absorbed and subsequently employed in the private sector.

• Dumapis vs. Lepanto Consolidated Mining Co., 884 Phil. 156 (2020) — Cited for the uniform rule on the inclusions in the computation for backwages.

• Lawyers Against Monopoly and Poverty vs. Secretary of Budget and Management, 686 Phil. 357 (2012) — Cited for the principle that the power of appropriation is vested in the Legislature, and budget execution comes under the domain of the Executive branch.

• BPI Employees Union-Metro Manila vs. Bank of the Philippine Islands, 673 Phil. 599 (2011) — Cited for the principle that the award of legal interest is a natural consequence of a final judgment and is not defeated notwithstanding the fact that the parties were at variance in the computation of what is due under the judgment.

• Article IX-D, Section 2(1), 1987 Constitution — Grants the COA 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. Applied to hold that the COA's powers over debts and claims from or owing the government is limited to its "examination, audit, and settlement," and it is not the appropriate entity to determine the source of funds.

• Article IX-B, Sections 7 and 8, 1987 Constitution — Prohibits double office-holding and double compensation in the civil service. Applied to support the ruling that rehired or absorbed employees are not entitled to backwages, as this would violate these constitutional prohibitions.

• Section 3, Rule 64, Rules of Court — Governs the time to file petitions for review of judgments and final orders or resolutions of the COA, requiring filing within 30 days from notice. Applied to determine that the Petition in G.R. No. 253395 was filed out of time.

• Section 63, Republic Act No. 9136 (EPIRA) — Provides separation benefits for displaced employees and states that those who avail of such privileges shall start their government service anew if absorbed by any government-owned successor company. Applied to hold that rehired employees are considered new employees and cannot claim the benefits of their previous positions.

• Section 49, Republic Act No. 9136 (EPIRA) — States that PSALM takes ownership of NPC's "generation assets, liabilities, IPP contracts, real estate and all other disposable assets." Applied to establish PSALM's direct liability for the judgment obligation.

• Section 50, Republic Act No. 9136 (EPIRA) — Authorizes PSALM to manage the orderly sale, disposition, and privatization of NPC generation assets with the objective of liquidating all NPC financial obligations. Applied to reject PSALM's contention that the judgment obligation should be paid exclusively from the sale of NPC assets.

• Section 26, Presidential Decree No. 1445 (Government Auditing Code) — Defines the general jurisdiction of the COA over auditing procedures, systems and controls, and the examination, audit, and settlement of all debts and claims of any sort due from or owing to the Government. Applied to hold that the COA's powers are limited to examination, audit, and settlement.

• Section 4(6), Presidential Decree No. 1445 (Government Auditing Code) — Requires that claims against government funds shall be supported with complete documentation. Applied to direct the NPC to turn over to the COA all relevant documents for verification of claims and proper computation of their entitlement.

• Article 259(e), Labor Code — Recognizes the collection of agency fees in an amount equivalent to union dues and fees, from employees who are not union members. Applied to explain the legal basis of the union's right to agency fees as quasi-contractual.

Gesmundo, C.J., Leonen, SAJ., Caguioa, Hernando, Lazaro-Javier, Inting, M. Lopez, Gaerlan, Rosario, J. Lopez, Dimaampao, Marquez, and Kho, Jr., JJ., concurred. Singh, J., was on leave.