PCSO vs COMMISSIONERS OF COA

GR No. 216776, April 19, 2016

Facts:

The PCSO Board of Directors, through Resolution No. 135, approved the
payment of monthly COLA to its officials and employees for a period of three (3) years
in accordance with the Collective Negotiation Agreement. Pursuant thereto, the PCSO
released the sum of P381,545.43 to all qualified officials and employees of its Nueva
Ecija Provincial District Office. On post audit, the Auditor of the PCSO-Nueva Ecija
issued Notice of Disallowance invalidating the payment of said amount on the grounds
that it is contrary to DBM Circular No. 2001-03 and it amounts to double compensation
that is prohibited under the 1987 Constitution. The PCSO appealed, but the COA
Regional Director affirmed the disallowance. Similarly, the COA Commission Proper
denied the petition for review and motion for reconsideration of PCSO. Hence, this
petition.

Issue:

Whether or not the payment of COLA as allowance was valid.

Held:

No. To determine whether the COLA is considered as an allowance that is

excluded from the standardized salary rates of the PCSO officials and employees,
reference must be made to the list in the first paragraph of Section 12 of R.A. No. 6758.
Since the COLA is not among those expressly excluded from integration by R.A. No.
6758, it should be considered as deemed integrated in the standardized salaries of the
PCSO officials and employees under the general rule of integration.