Patadon v. Commission On Audit

INTING, J.:

Before the Court is a Petition for Certiorari1 under Rule 64, in relation to Rule 65, of the Rules of Court assailing the Commission on Audit (COA) Commission Proper (COA Proper) Decision No. 2014-2442 dated September 11, 2014 and the Resolution3 dated March 9, 2015 in COA CP Case No. 2013-394. In the assailed issuances, the COA Proper affirmed the Special Audits Office (SAO) Decision No. 2013-0114 dated September 16, 2013 that upheld SAO Notice of Disallowance (ND) No. ORG-12-002-MDS/LF (08 & 09)5 dated January 13, 2012 relative to the cash advances amounting to P79,162,435.00 of Adham G. Patadon (Patadon). The Antecedents The present case stems from SAO's audit of the operations of the Office of the Regional Governor, Autonomous Region of Muslim Mindanao (ORG-ARMM).

In Audit Report No. 2010-01,6 the SAO made the following observations, among others: • From January 2008 to September 2009, ORG-ARMM issued checks in the aggregate amount of P1,083,502,563.357 in favor of various payees. • P866,512,945.548 of the amount represented cash advances granted for the own operations of the ORG-ARMM. • P854,748,736.389 of the total cash advances were granted to three accountable officers of the ORG-ARMM, viz.: ORG-ARMM Officer Cash Advances Received Patadon, Supply Officer V, then Chief Administrative Officer/Special Disbursing Officer P744,559,272.19 Nelia N. Garde, Administrative Officer V 83,128,851.18 Tahirodin Benzar A. Ampatuan, Security Officer V, then Executive Assistant VI 27,060,613.01 Total P854,748,736.38 According to the SAO, the magnitude of cash advances of the ORG-ARMM indicated that it failed to observe the general rule that payments must be made by check, unless it is impossible and impractical to do so.10 Furthermore, after an examination of the documents submitted to liquidate the cash advances made out to Patadon (P744,559,272.19), it found that a portion thereof pertained to successive purchases of various relief goods and office supplies from Superama.11 Based on the foregoing findings, the COA Auditor issued ND No. ORG-12-002-MDS/LF (08 & 09) dated January 13, 2012 to disallow cash advances released to Patadon and used in relation to the alleged purchases from Superama amounting to P79,162,435.00 computed as follows: Check No.