CASE DIGEST : MARY GRACE D. CORPUZ v. COA GR No. 253777 GAERLAN

 FACTS : The case involves a Petition for Certiorari filed on March 11, 2020 under Rules 64 and 65 of the Revised Rules of Court, seeking the reversal of COA Decision No. 2018-370 and Notice No. 2020-014, which affirmed COA-RO3 Decision No. 2015-04 disallowing payments to Atty. Teodoro G. Mendoza under a legal retainer contract with PhilRice. PhilRice, through its Executive Director Atty. Ronilo Beronio, executed the contract with Atty. Mendoza in 2009 without prior COA concurrence, which was only later issued in December 2009, directing reductions in fees. COA subsequently issued Notices of Disallowance totaling ₱209,765.00, holding several PhilRice officials—including petitioners Mary Grace Corpuz, Babylinda Reyes, Sophia Borja, Leo Javier, and Caesar Tado—liable for certifying and approving the payments. The petitioners appealed to COA-RO3 and the COA proper, both of which denied their appeals for failure to comply with the Legal Retainer Review and for lack of merit. The petitioners now seek relief before this Court, arguing that sustaining the disallowances would unjustly enrich the government, the contract and disbursements were fair and lawful, and the disbursements were made in good faith.

ISSUE : WON the Subject Contract, at the time of execution, was not entered into in accordance with the prevailing law, rules, and jurisprudence.

HELD : The Court ruled that while PhilRice officers sought the concurrence of the OGCC and COA, the Subject Contract with Atty. Mendoza was executed without prior approval, violating applicable laws and COA Circulars. Petitioners Corpuz, Borja, Javier, Tado, and Reyes were not involved in hiring Mendoza and are therefore absolved from liability under Notice of Disallowance No. 14-001-101-(09), along with Conyfel Jiao, Eulito Bautista, and Ruben Miranda. Atty. Beronio, as Executive Director, and Atty. Mendoza remain liable, with Mendoza entitled only to a reasonable retainer of ₱10,000/month and ₱1,000/appearance. For Notice of Disallowance No. 14-002-101-(2013), only Reyes and Tado remain liable for reimbursement of notarial commission fees, since such costs were not covered under the contract. The Court affirmed COA’s decisions with modification, leaving unresolved the potential liability of Beronio, Mendoza, Rasco, and the PhilRice Board members, and allowing COA to issue supplemental notices if warranted.