COA should follow more humane procedure conformable to due process clause
In Arriola vs. COA (202 SCRA 147) this Court ruled that price findings reflected in a report are not, in the absence of the actual canvass sheets and/or price quotations from identifier suppliers, valid bases for outright disallowance of agency disbursements for government projects. There, furthermore, the Court has held: "A more humane procedure, and totally conformable to the due process clause, is for the COA representative to allow the members of the Contracts Committee mandatory access to the COA source documents/canvass sheets. xxx "xxx xxx xxx "By having access to source documents, petitioners could then satisfy themselves that COA guidelines/rules on excessive expenditures had been observed. The transparency would also erase any suspicion that the rules had been utilized to terrorize and/or work injustice, instead of ensuring a 'working partnership' between COA and the government agency, for the conservation and protection of government funds, which is the main rationale for COA audit." [G.R. No. 114864. December 6, 1996]