CASE DIGEST
Angeles v. Commission
on Audit
G.R. No. 228795, [December 1, 2020]
EN BANC, LOPEZ, M.V
Administrative Law; Robbery of Payroll Money; Accountability of Municipal Treasurer
The accountability for government funds
involves the diligence of a good father of a family. The absence of a
security escort alone does not indicate negligence, and a balanced approach is
necessary to prevent injustice to government employees not guilty of
negligence. The decision rejects the idea that a higher degree of diligence is
required merely due to the substantial amount involved and emphasizes the need
for a reasonable assessment of the circumstances surrounding the loss of
government funds.
On March 12, 2010, Lily De Jesus (cashier) and Estrellita Ramos (revenue collection officer) of the Municipality of San Mateo, Rizal, along with driver Felix Alcantara, withdrew P1,300,000.00 payroll money from Land Bank. While returning to the office, an armed man shot Felix, resulting in injuries, and later another man forcibly took the payroll money from Lily, causing her death. The suspects were later arrested and indicted for Robbery with Homicide. Estelita, the officer-in-charge municipal treasurer, sought relief from accountability for the lost money, citing the absence of specific regulations on safeguarding payroll money while in transit. The COA denied her petition for review, emphasizing the necessity of a higher degree of precaution due to the substantial amount involved.
Whether or not Estelita should be held
accountable for the lost payroll money due to the absence of a security escort
during the bank transaction.
NO. The Court reversed the Commission on
Audit's (COA) decision, granting Estelita relief from accountability. The
Court held that Estelita and Lily had exercised reasonable care and caution
under the circumstances. They followed the standard procedure, using the
municipal service vehicle and obtaining a travel pass. The robbery was
unexpected, occurring in broad daylight on a public street. The Court
emphasized that the absence of a security escort alone does not indicate
negligence, and it criticized the COA's stringent condition for requiring one.
The COA's conclusion, in hindsight, that a security escort should have been
requested was insufficient to establish negligence. The Court stressed the need
for a balanced approach to prevent injustice to government employees not guilty
of negligence.
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