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Local Autonomy in Demaala v. COA

The Supreme Court case Demaala v. Commission on Audit ruled in favor of Lucena D. Demaala, the mayor of Narra, regarding a dispute over the collection of an additional levy for the special education fund. The Court emphasized local autonomy and the authority of local government units to establish their own revenue sources, stating that Demaala should not be held personally liable for any alleged deficiency in collections. The COA's decision was annulled and set aside as it improperly held Demaala accountable for enforcing a valid provincial ordinance.

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7 views2 pages

Local Autonomy in Demaala v. COA

The Supreme Court case Demaala v. Commission on Audit ruled in favor of Lucena D. Demaala, the mayor of Narra, regarding a dispute over the collection of an additional levy for the special education fund. The Court emphasized local autonomy and the authority of local government units to establish their own revenue sources, stating that Demaala should not be held personally liable for any alleged deficiency in collections. The COA's decision was annulled and set aside as it improperly held Demaala accountable for enforcing a valid provincial ordinance.

Uploaded by

Chill Bill
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Title

Demaala vs. Commission on Audit


Case
G.R. No. 199752
Ponente
LEONEN, J
Decision Date
Feb 17, 2015
The case of Demaala v. Commission on Audit revolves around the dispute over the
collection of an additional levy for the special education fund, with the Supreme Court
ruling in favor of Demaala and emphasizing the principle of local autonomy and the
power of local government units to create their own sources of revenue.

Facts:

● The case involves a dispute over the collection of an additional levy for the
special education fund in the Municipality of Narra, Palawan.
● The petitioner, Lucena D. Demaala, was the mayor of Narra at the time.
● The Commission on Audit (COA) issued a Notice of Charge stating that there
was a deficiency in the collection of the special education fund.
● The COA held Demaala personally liable for the shortfall.

Issue:

● Whether the COA committed grave abuse of discretion in holding that there was
a deficiency in the collection of the additional levy for the special education fund.
● Assuming there was a deficiency, whether the COA committed grave abuse of
discretion in holding Demaala personally liable for the shortfall.

Ruling:

● The Supreme Court ruled in favor of Demaala.

Ratio:

● The Court emphasized the principle of local autonomy and the power of local
government units to create their own sources of revenue.
● Local government units have the discretion to set the rate of the levy for the
special education fund.
● The Court held that it was improper to hold Demaala personally liable for the
deficiency in collections.
● Demaala was merely enforcing a provincial ordinance that was yet to be
invalidated.
● Ordinances are presumed valid unless declared otherwise by the courts.
● Therefore, the COA's decision was annulled and set aside

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