The same is true in the present case where Verceles' reliance on, among others, the opinion of the Department of Interior and Local Government, does not exculpate him from his personal liability. Section 336 of the LGC and Section 26 of the Province's appropriation ordinance in CY 2002, in clear and precise language, required the authority from the SP before the governor can make augmentations or realignments of funds. In summary, and exceptfor the incorrectly disallowed thirdMOA, we find that the COA's assailed decision was made in faithful compliance with its mandate and in judicious exercise of its general audit power as conferred on it by the
NOTES ON POLITICAL LAW Excerpts from the 2016 Decisions of the Supreme Court by Atty. CARLO L. CRUZ75 Constitution. The COA was merely fulfilling its mandate in observing the policy that government funds and property should be fully protected and conserved; and that irregular, unnecessary, excessive or extravagant expenditures or uses of such funds and property should be prevented. Thus, no grave abuse of discretion may be imputed to the COA. (Verceles v. Commission on Audit, G.R. No. 211553, September 13, 2016) Although the disbursements made by ZCWD may have been made without legal basis, the petitioner may be absolved from refunding the disbursements if it is shown that they were made in good faith. xxx. Unlike the officers of ZCWD who authorized the payment of the disallowed disbursements, these employees were merely passive recipients who honestly believed they were entitled to the said benefits as their payment was ratified by their officers. They were in good faith as they were unaware that the benefits they received were either without basis or had failed to comply with the requirements of the law. Thus, the employees who received the CNA incentives and the 14th month pay and the employees who were covered by the life insurance program other than the GSIS need not refund the amounts paid out for these benefits. (Zamboanga City Water District v. Commission on Audit, G.R. No. 213472, January 26, 2016) MNWD employees need not refund the amounts corresponding to the COLA they received. They had no participation in the approval thereof and were mere passive recipients without knowledge of any irregularity. Hence, good faith should be appreciated in their favor for receiving benefits to which they thought they were entitled. Further, good faith may also be appreciated in favor of the MNWD officers who approved the same. They merely acted in accordance with the resolution passed by the Board authorizing the back payment of COLA to the employees. Moreover, at the time the disbursements were made, no ruling similar to MIAwas yet made declaring that the COLA was deemed automatically integrated into the salary notwithstanding the absence of a DBM issuance. In Mendoza v. COA, the Court considered the same circumstances as badges of good faith. (Metropolitan Naga Water District v. Commission on Audit, G.R. No.