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Case Digest: The petitioners are two unions of employees from the Department of Environment and Natural Resources (DENR). They challenged the validity of a circular issued by the Department of Budget and Management (DBM) that reduced their monthly longevity pay. The longevity pay is a benefit granted to DENR employees who have rendered at least five years of continuous service in the department. The DBM circular reduced the longevity pay from 5% to 1% of their basic salary for every five years of service.

The petitioners argued that the DBM circular violated their right to non-diminution of benefits and that it was issued without prior consultation with them. They also claimed that the Commission on Audit (COA) erred in disallowing their claims for payment of their full longevity pay.

The respondents countered that the DBM circular was issued in accordance with law and that it harmonized the longevity pay with other similar benefits under existing laws. They also asserted that the COA acted within its audit jurisdiction and authority in disallowing the petitioners' claims.

The Supreme Court ruled in favor of the respondents and dismissed the petition. The Court held that the DBM circular was valid and did not violate the petitioners' right to non-diminution of benefits. The Court explained that the longevity pay was not a vested right but a conditional benefit subject to modification by law or regulation. The Court also found that there was no need for prior consultation with the petitioners as they were not directly affected by the DBM circular.

The Court also upheld the COA's disallowance of the petitioners' claims for full payment of their longevity pay. The Court said that COA had audit power over all government funds and expenditures, including those pertaining to salaries and allowances. The Court added that COA's findings were supported by substantial evidence and were accorded respect and finality unless overturned on appeal.

Source: Conversation with Bing, 07/03/2023(1) G.R. No. 204152 - Lawphil. https://lawphil.net/judjuris/juri2021/jan2021/gr_204152_2021.html Accessed 07/03/2023.
(2) G.R. No. 204152 - DENR EMPLOYEES UNION (DENREU) AND ... - ChanRobles. https://www.chanrobles.com/cralaw/2021januarydecisions.php?id=273 Accessed 07/03/2023.
(3) Digest | DENR Employees Union v. Abad- G.R. No. 204152 - Philippine Law. https://www.digest.ph/decisions/denr-employees-union-v-abad Accessed 07/03/2023.

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