Lim v. Commission on Audit
REITERATIONFacts
The Antecedents: The Government Service Insurance System (GSIS) in Zamboanga City, through its Branch Manager Ramon T. Lim, requisitioned an electric generator for use during power interruptions. A canvass was conducted, and V.A. Rivera Enterprises offered the lowest price for a 20 KVA Petter/Stamford generator set. The unit was delivered and used by GSIS from January 8, 1992, to May 18, 1992. Subsequently, a bidding was held for a 15 KVA generator set, and V.A. Rivera Enterprises was again declared the winner, returning the previously delivered unit and waiving rental fees. Procedural History: The GSIS Branch Auditor disallowed the payment of P239,000.00 for the generator, citing that the unit was not brand-new and did not conform to the 15 KVA specification in the Invitation to Bid. Petitioner Lim's motion for reconsideration was denied. An appeal was lodged with the Commission on Audit (COA), which affirmed the auditor's disallowance in a Decision dated March 1, 1996. A subsequent motion for reconsideration filed by Lim was denied by the COA in a Resolution dated July 29, 1997. The Petition: Petitioner Ramon T. Lim filed a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure, challenging the COA's Decision and Resolution. He argued that the COA acted with grave abuse of discretion amounting to lack of jurisdiction in disallowing the payment and in failing to apply the principle of quantum meruit. Lim contended that the generator was brand-new, albeit locally assembled, and that the 20 KVA unit was superior to the specified 15 KVA.
Issue(s)
Whether the Commission on Audit acted with grave abuse of discretion amounting to lack of jurisdiction in disallowing the payment for the generator set because it was not brand-new and did not conform to the specifications. Whether the principle of quantum meruit is applicable for the use of the generator set, and whether this issue is properly raised in a petition for certiorari under Rule 65.
Ruling
The petition is DISMISSED. The assailed Decision dated March 1, 1996, and Resolution dated July 29, 1997, of the Commission on Audit are AFFIRMED.
Ratio Decidendi
On the disallowance of payment for the generator set: The Supreme Court affirmed the COA's disallowance, reiterating that factual findings of administrative agencies like the COA are generally respected if supported by substantial evidence. Here, the COA found the generator set was not brand-new and did not conform to the specifications (15 KVA). The Court emphasized it is not a trier of facts and the COA's findings were supported by substantial evidence. Since the delivered 20 KVA generator set did not conform to the specifications, the COA's decision disallowing its payment was in order. On the applicability of quantum meruit for rentals and the scope of certiorari: The Supreme Court found the petitioner's contention regarding quantum meruit to be without merit. A petition for certiorari under Rule 65 is limited to resolving whether the act was done without or in excess of jurisdiction, or with grave abuse of discretion. The issue of whether GSIS is liable for rentals based on quantum meruit was deemed outside the scope of a certiorari proceeding under Rule 65. Therefore, the Court did not delve into the merits of the quantum meruit claim, as it was not the proper subject for review.
Main Doctrine
The factual findings of administrative agencies like the Commission on Audit (COA), when supported by substantial evidence, are generally accorded respect and finality. A petition for certiorari under Rule 65 is limited to reviewing acts done without or in excess of jurisdiction or with grave abuse of discretion, and does not include the payment of rentals based on quantum meruit.