Background

After completing the New Iloilo Airport project, TSJV found that some of its billings remained unpaid. They sought arbitration through CIAC, which granted a substantial award in their favor. When TSJV attempted to enforce this award, they encountered resistance from government agencies, leading them to seek enforcement through COA. However, COA only partially approved the payment, effectively modifying the CIAC's final and executory award. TSJV then brought the case to the Supreme Court, challenging COA's decision.

Facts

• 1. TSJV won the contract for the construction of the New Iloilo Airport.
• 2. After project completion, some TSJV billings remained unpaid.
• 3. TSJV filed for arbitration with CIAC, seeking payment of various claims.
• 4. CIAC rendered a Final Award in favor of TSJV, which became final and executory.
• 5. TSJV sought enforcement of the award through COA.
• 6. COA partially approved payment, disallowing more than half of the arbitral award.

Arguments of the Petitioners

• 1. COA's decision contravened Section 19 of Executive Order No. 1008 and the rule on immutability of final judgments.
• 2. COA's decision was contrary to its own previous decision in a similar case.
• 3. COA's application of RA 9184 was retroactive and thus improper.
• 4. The disallowance of attorney's fees and costs of litigation was inconsistent with the Civil Code and CIAC rules.

Arguments of the Respondents

• 1. COA has primary jurisdiction over all money claims against the government.
• 2. Even for final judgments, COA approval is a condition sine qua non for payment.
• 3. COA exercises quasi-judicial function in approving or disapproving claims based on evidence.
• 4. COA's action was in accord with law and evidence, thus not constituting grave abuse of discretion.

Issues

• 1. Does the COA have exclusive jurisdiction over money claims due from or owing to the government?
• 2. In exercising its audit power, may the COA disturb final and executory decisions of courts, tribunals, or other adjudicative bodies?

Ruling

• 1. The COA's primary jurisdiction over money claims due from or owing to the government does not preclude the exercise of jurisdiction over the same subject matter by another adjudicatory body, tribunal, or court.
• 2. The COA's audit review power over money claims already confirmed by final judgment of a court or other adjudicative body is necessarily limited.
• 3. The COA gravely abused its discretion when it modified or amended the CIAC's final and executory judgment.

Rationale

• 1. There is no constitutional or statutory provision granting COA exclusive jurisdiction over money claims.
• 2. Other courts and tribunals may have concurrent jurisdiction with COA over money claims against the government.
• 3. COA's jurisdiction over final money judgments pertains only to the execution stage, ensuring that public funds are not diverted from their legally appropriated purpose.
• 4. The principle of immutability of final judgments applies to decisions of all tribunals exercising adjudicatory powers, including CIAC.
• 5. COA exceeded its constitutional mandate by reweighing evidence and pointing out purported errors in the arbitral award.

Doctrines

• 1. Primary Jurisdiction: While COA has primary jurisdiction over money claims against the government, this doesn't preclude other bodies from exercising jurisdiction over the same subject matter.
• 2. Immutability of Final Judgments: A decision that has become final and executory is immutable and unalterable, and may not be modified in any respect.
• 3. Res Judicata: A final judgment on the merits is conclusive as to the rights of the parties and their privies, and constitutes an absolute bar to subsequent actions involving the same claim, demand, or cause of action.
• 4. Separation of Powers: The COA's constitutional mandate doesn't allow it to encroach upon the judicial function of determining the validity of contracts.

Key Excerpts

• 1. "To accept the COA's theory that it has absolute discretion to disregard final and executory judgments rendered by courts and other adjudicative bodies in valid exercise of their jurisdiction would wreak havoc on the efficient and orderly administration of justice. The COA then becomes a super body over and above the rule of law."
• 2. "While we rule that the COA may no longer modify the amount of the award, it is not within the Court's power to determine the manner for enforcement or satisfaction thereof as this should still be pursued in accordance with the rules and procedures laid down in P.D. No. 1445 and other relevant laws."

Precedents Cited

• 1. Development Bank of the Philippines v. COA (2002): Used to show that COA doesn't have sole and exclusive power to examine and audit government banks.
• 2. CSC v. Pobre (2004): Cited to demonstrate that COA and other agencies may have shared jurisdiction in certain matters.
• 3. Euro-Med Laboratories, Phil., Inc. v. Province of Batangas (2006): Used to specify that COA's original jurisdiction is limited to liquidated claims.
• 4. Uy v. COA (2000): Cited to explain the two types of money claims that may be brought before COA and to emphasize that COA cannot set aside final judgments of other tribunals.
• 5. University of the Philippines v. Dizon (2012): Discussed to clarify that COA's jurisdiction in execution of money judgments is limited to ensuring proper appropriation of funds.

Statutory and Constitutional Provisions

• 1. Article IX, Section 2(1) of the 1987 Constitution: Defines COA's power to examine, audit, and settle all accounts pertaining to government revenue, receipts, expenditures, and property.