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CSC vs. COA: Jurisdiction on Leave Benefits

The document discusses a case regarding the jurisdiction of the Civil Service Commission (CSC) and the Commission on Audit (COA) over claims for terminal leave benefits of a former government official. While the CSC determines leave benefits, the COA has the duty to examine government accounts and expenditures related to such benefits. Both the CSC and COA have jurisdiction over claims involving government funds like terminal leave pay, with neither having exclusive authority.

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289 views1 page

CSC vs. COA: Jurisdiction on Leave Benefits

The document discusses a case regarding the jurisdiction of the Civil Service Commission (CSC) and the Commission on Audit (COA) over claims for terminal leave benefits of a former government official. While the CSC determines leave benefits, the COA has the duty to examine government accounts and expenditures related to such benefits. Both the CSC and COA have jurisdiction over claims involving government funds like terminal leave pay, with neither having exclusive authority.

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CSC v. Pobre | G.R. No. 160568 | Sept.

15, 2004
[Audit jurisdiction]

DOCTRINE: While the determination of leave benefits is within the functions of the CSC as the central personnel
agency of the government, the duty to examine accounts and expenditures relating to such benefits properly pertains
to the COA.

FACTS: Pobre is a former government official who retired from the government service 3 times (As COA Chairman
- 1986; as Board of Accountancy Chairman - 1990; then as Associate Chairman of PRC - 2001). He received his
terminal leave pay for the 1st two times he retired. As for his 3rd retirement, Pobre claimed payment of his terminal
leave pay based on his highest monthly salary as PRC Chairman but to be reckoned from 1958 when he first entered
government as budget examiner.
Successor PRC Chairman Fortuna-Ibe sought the opinion of CSC and COA.
CSC issued a Resolution stating that Pobre was entitled to terminal leave benefits to be accrued from date of
assumption to office as PRC Chairman and NOT the total from 1958. Pobre filed MR – denied.
Pobre elevated the case to CA. CA REVERSED and held that it was the COA, not CSC, which had jurisdiction to
adjudicate Pobre’s claim for terminal leave benefits.
Now CSC files the instant petition. CSC contends that it had jurisdiction by virtue of the 1987 Admin Code that
expanded the power of CSC. One of which is “to administer the retirement program for government officials and
employees.”

ISSUE: Who has jurisdiction, CSC or COA?

HELD: Both. CSC does not have exclusive jurisdiction.


While the determination of leave benefits is within the functions of the CSC as the central personnel agency of the
government, the duty to examine accounts and expenditures relating to such benefits properly pertains to the
COA. Where government expenditures or use of funds is involved, the CSC cannot claim jurisdiction simply because
leave matters are involved. Thus, even as we recognize CSC’s jurisdiction in this case, its power is not exclusive as it
is shared with the COA.
The COA, the CSC and COMELEC are equally pre-eminent in their respective spheres. Neither one may claim
dominance over the others. In case of conflicting rulings, it is the Judiciary which interprets the meaning of the law
and ascertains which view shall prevail.
In the instant case, there is no conflicting ruling to speak of because the COA is yet to render its opinion on PRC’s
query regarding Pobre’s claim for terminal leave benefits.
The Court decided to abstain from any pronouncement on this issue and to wait for COA to rule on respondent’s
claim.

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