WHEN the House of Representatives’ committee on justice released the Commission on Audit’s (COA) April 10, 2026 decision upholding the P73.28-million disallowance against the Office of the Vice President, the reaction was swift and predictably political. Allies of Vice President Sara Duterte cried harassment. Critics called it vindication. Lost in the noise was a more important story — one about an institution, a process, and the painstaking machinery of fiscal accountability that most Filipinos never see until it lands on the front page.
That story deserves to be told, for the COA process is built for rigor, not speed. The COA disallowance process is deliberately slow by design. It is hierarchical, technical and exhausting, and that is precisely the point.
It begins long before a notice of disallowance is ever issued. Auditors first observe a transaction, issue an audit observation memorandum, and give the agency an opportunity to explain. This alone can take months. Only when the auditor remains unsatisfied does a notice of disallowance follow, an official document declaring that a government expenditure was “illegal, irregular, unnecessary, excessive, extravagant, or unconscionable.” Even then, it is not final. But the committee on justice is trying to say that the disallowance was final.
The person held liable has six months to appeal to the cluster or regional director. If that appeal fails, they may elevate the matter to the COA commission proper, the three-member body of the chairman and two commissioners. Only after the commission proper renders judgment, and that judgment is not appealed within six months, does a disallowance become final and executory. At that point, a notice of finality of decision is issued, followed by a COA order of execution that compels the return of public funds. If a party still refuses to comply, the matter goes to the Supreme Court on a petition for certiorari under Rule 64. Clearly, the judgment of the House was uncalled for.
From first audit observation to final Supreme Court ruling, this process can span a decade. The OVP’s 2022 confidential fund spending took three years just to reach the commission proper level. That is not bureaucratic failure — that is due process, applied with rigor to public money.
No recent controversy has tested the COA’s disallowance machinery more than the use and misuse of confidential and intelligence funds.
The governing framework is Joint Circular 2015-01, which limits the use of confidential funds to surveillance activities, rewards to informants, safehouse maintenance, and similar operations directly tied to national security. The rules are strict: agencies must document not just the spending, but the “success” of the intelligence activities the spending supported. Supporting documents are submitted in sealed envelopes to COA’s Intelligence and Confidential Funds Audit Office, one of the few audit units that operates behind its own veil of secrecy.
That secrecy has been exploited. The OVP spent P125 million in confidential funds within 11 days in December 2022, funds that did not even appear in that year’s General Appropriations Act, having been released from the executive’s discretionary contingent fund upon President Ferdinand Marcos Jr.’s approval without congressional authorization. COA found that P69.78 million labeled as “rewards” lacked any documentation of successful intelligence-gathering activities, and P3.5 million went to office furniture and equipment charged improperly to the confidential fund. The disallowance followed.
The pattern is not new. Local government units in Sarangani and Laak, Davao de Oro, had their own confidential fund disallowances reach the Supreme Court — and in both cases, the Court sided with COA, ruling that confidential fund spending must be directly connected to law enforcement and national security, and that prior regulatory approvals cannot be assumed. The Supreme Court has been consistent: Secrecy is not a shield against accountability.
Not every COA finding ends in permanent disallowance. In 2015, the Department of Justice under then-secretary Leila de Lima was flagged for failing to liquidate P123.8 million in confidential fund cash advances and missing disbursement vouchers for P91.8 million. It looked damning at the time. But by 2016 and 2018, COA’s own annual reports confirmed that the DOJ had fully implemented the recommended remedial actions. No notice of disallowance was issued. The matter was resolved.
Similarly, President Benigno Aquino III’s Disbursement Acceleration Program was declared partially unconstitutional by the Supreme Court in 2014, a stunning rebuke. But the Ombudsman ultimately cleared Aquino and Budget Secretary Florencio Abad of criminal and administrative liability, finding no corrupt intent behind a program that, while constitutionally flawed in its mechanics, was genuinely aimed at accelerating public spending for the people’s benefit.
These cases are not contradictions of the system — they are proof that it works. The COA process is not a one-way conveyor belt to conviction. It is a mechanism for arriving at the truth about public money, wherever that truth leads.
What the OVP case has exposed, more starkly than any other in recent memory, is the structural weakness in how the Philippines governs its confidential funds. The Office of the President spent P4.56 billion in confidential and intelligence funds in 2023 alone, nearly half of the entire national government’s CIF allocation. Yet because no notice of disallowance has been issued against those expenditures, public scrutiny has been limited and congressional inquiry has been muted.
This is the paradox at the heart of CIF governance: The very secrecy that makes disallowance difficult to obtain also makes the absence of a disallowance difficult to interpret. A clean audit result on confidential funds does not mean the funds were well spent. It may simply mean the documentation was in order.
The COA disallowance is not a verdict of guilt. The commission has said as much. A notice of disallowance means that the expenditure was not in compliance with the rules — not necessarily that it was fabricated or fraudulent. That distinction is important, and it is one that politicians on all sides of these controversies routinely ignore.
But compliance with the rules is not a small thing. Rules about public money exist precisely because public money belongs to the people, not to the officials who spend it, not to the informants on the acknowledgment receipts, and not to the satellite offices or safehouses that may or may not exist.
The COA disallowance process is the people’s auditor at work: methodical, deliberate and stubbornly indifferent to political pressure. When its gavel falls, it should be heard, not as the opening salvo of a political war, but as the sound of a constitutional institution doing exactly what it was created to do.
The question is not whether COA got it right. It usually does. The question is whether the rest of government, and the public, will have the patience and the will to let the process run its full course. Until that course is finished, turning an unfinished audit into an impeachable offense is not accountability; it is preemption. If this is truly about protecting public funds, then the remedy is simple: follow the rules, respect the institutions, and demand transparency where secrecy is most easily abused. But if the goal is to decide the verdict early, years before the process, and long before the voters, then we should call it what it is: politics masquerading as principle.
