The Commission on Audit (COA; Filipino: Komisyon sa Awdit[2] or officially Komisyon ng Pagsusuri) is an independent constitutional commission established by the Constitution of the Philippines. It has the primary function to examine, audit and settle all accounts and expenditures of the funds and properties of the Philippine government.[3]
The Commission on Audit is a creation of the 1973 constitution. It was preceded by the Office of the Auditor in 1899, renamed as the Bureau of the Insular Auditor in 1900, then to the Bureau of Audits in 1905. The 1935 constitution created the General Auditing Office (GAO), and was led by the Auditor General. The 1973 constitution renamed the GAO to the Commission on Audit, a collegial body led by a chairman, with two commissioners. That setup was retained by the 1987 constitution.
In Funa v. Villar, the Supreme Court ruled that a Commissioner can only be appointed as chairman if the unexpired term for the office of chairman and the term that the Commissioner had already served does not exceed seven years. In such case, the Commissioner promoted as chairman would serve the unexpired term of the chairman, forfeiting the duration of his original term as Commissioner. This was based on a case where Reynaldo A. Villar, who was appointed commissioner in 2004, was then appointed as chairman in 2008, making him serve out eleven years in total. Villar resigned before he served out the full seven-year term as chairman, but prior to the resolution of the case.[5]
The 1987 Constitution staggered the terms of the members of the Constitutional Commissions. Of the first appointees, the chairman would serve seven years (1st line), a Commissioner would serve five years (2nd line), and another Commissioner would serve three years (3rd line).
The members of the commission can only be removed from office via death, resignation or impeachment.
The General Auditing Office was headed by the Auditor-General. The Auditor-General has a 10-year term, is appointed by the president, is confirmed by the Commission on Appointments, and can only be removed via impeachment by Congress. This agency preceded the present-day commission.
In Jess Christoper S. Biong v. Commission on Audit, the Supreme Court ruled that the COA's audit power does not include the imposition of administrative penalties by its auditors upon culpable public officers.[6]