How to compel COA to audit Red Cross?
Assuming that the jurisdiction of the Commission on Audit (COA) as provided under the 1987 Constitution covers the Philippine Red Cross (PRC),[1][2] what are the possible remedies available under the law to compel it to do so in case it continues to refuse to so audit?
The remedy is mandamus under Section 6 of Article VIII of the 1987 Constitution which says: The Supreme Court shall have the following powers: (1) Exercise original jurisdiction over cases affecting ambassadors, other public ministers and consuls, and over petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus. [xxx.]" This should not be confused with the petition for mandamus referred to under Rule 65 of the Rules of Court, which is a remedy to compel a ministerial act or duty, and not purely discretionary matter.[3] Nevertheless, it can be reasonably argued that COA's functions are not purely discretionary in nature.
The remedy of mandamus referred to under Article III is broader in scope.
[1] https://www.projectjurisprudence.com/2021/09/coa-can-audit-payments-but-not-red-cross-itself.html.
[2] https://www.projectjurisprudence.com/2021/09/may-red-cross-pnrc-be-audited-by-government.html.
[3] https://www.projectjurisprudence.com/2020/04/rule-65-purely-ministerial-duty.html.