EXECUTIVE SUMMARY INTRODUCTION - coa.gov.ph · MOOE CO 20% EDF 5% LDRRMF ... School Board contrary to Section 100, ... Chief Executive even when the liquidation vouchers/reports for

EXECUTIVE SUMMARY

INTRODUCTION

The Municipality of Margosatubig, Province of Zamboanga del Sur, was formerly

a municipal district of the City of Zamboanga from 1917 to 1936. It became a regular

and distinct municipality with eight original barrios during the Commonwealth

Government by virtue of Executive Order No. 17 dated December 23, 1936 signed by

President Manuel L. Quezon.

It was originally named as “Malagus Tubig” by the Subanens, believed to be the

first settlers in this land, patterned after the swift river current that kept changing its

course towards the mouth of Dumanquillas Bay.

An asphalt road connecting Margosatubig to Pagadian was facilitated by the

Zamboanga del Sur Development Project undertaken by the Philippine - Australian

Development Assistance Program (PADAP) in 1976. The electrification by the

Zamboanga del Sur Electric Cooperative (ZAMSURECO) followed in 1979.

It is a 3rd class municipality with 17 barangays and belongs to the 2nd district of

Zamboanga del Sur. The municipality has a total land area of approximately 11,169

square kilometers and a population of about 39,012 people in 6,560 households according

to the 2007 census. Major crops are rice, corn, and coconuts. Fishing and farming are the

main source of livelihood.

SCOPE OF AUDIT

A comprehensive audit was conducted on the accounts and operations of

Municipality of Margosatubig, Province of Zamboanga del Sur for 2015. The audit

consisted of review of operating procedures, evaluation of the LGU’s programs and

projects, interview of concerned government officials and employees, verification,

reconciliation, and analysis of accounts, and such other procedures considered necessary.

Specifically, the objective of the audit is to ascertain the propriety of the financial

transactions and compliance of the agency to prescribed laws, rules and regulations. It

was also made to ascertain the accuracy of the financial records and reports as well as

fairness of the presentation of the financial statements. Performance audit was likewise

conducted with the objective of informing management where improvement can be

instituted in the field of revenues, expenditures and management of resources.

As a result of the risk assessment conducted and in compliance with the identified

audit thrust of the Local Government Sector for CY 2015, the following audit

areas/accounts were looked into:

1. Complete Submission of Accounts;

2. Accuracy of LGU’s reported accomplishments vis-à-vis major programs and projects

as well as efficiency and economy in the implementation of the same;

3. Fund Transfers from National Government Agencies (NGAs) to LGUs;

4. Fund Transfers to Other LGUs;

5. Fund Transfers to Non-Government Organizations/People’s Organization;

6. Local Disaster Risk Reduction and Management;

7. Environmental Compliance (Ecological Solid Waste Management, National Greening

Program);

8. Gender and Development;

9. Special Education Fund;

10. 20% Development Fund;

11. Allocations to Local Government Units (ALGU);

12. Cash and Accounts;

13. Cash Advances;

14. Property, Plant and Equipment;

15. Revenue;

16. Claim of Councilors for attendance in the Philippine Councilors League (PCL)

activities;

17. Payment of Honoraria and Allowances;

18. Hiring of Casuals, Job Orders, Contractual and Consultants;

19. Credit Financing/Debt Servicing; and

20. Infrastructure Projects.

FINANCIAL HIGLIGHTS

The financial position and financial performance of the Agency as of December

31, 2015 are summarized as follows (in thousands of Pesos):

2015

Assets 334,418

Liabilities 201,541

Equity 132,877

Income 90,127

Expenses 67,935

The LGU’s appropriations and obligations for the year were as follows:

Current Legislative Appropriations

Particulars

Appropriations

Allotments

Obligations

General Fund

PS

MOOE

CO

20% EDF 5% LDRRMF

34,292,617.04

22,902,313.58

2,086,589.98

15,658,416.60

4,152,222.90

34,292,617.04

22,902,313.58

2,086,589.98

15,658,416.60

4,152,222.90

31,960,251.53

22,309,680.78

1,986,057.00

10,481,034.44

2,657,923.50

5% GAD 3,952,222.90 3,952,222.90 3,627,513.98

Economic

PS

MOOE

CO

3,590,340.09

2,491,099.61

1,149,796.40

3,590,340.09

2,491,099.61

1,149,796.40

3,542,071.61

2,437,723.04

-0-

Total 90,275,619.10 90,275,619.10 79,002,255.88

INDEPENDENT AUDITOR’S REPORT

We rendered a modified opinion on the fairness of the presentation of the

financial statements of the LGU as of December 31, 2015 due to the following:

1. Cash in Bank – Local Currency Current Account is overstated by P2,234,226.65 due

to the unrecorded book reconciling items for total addition of P591,748.33 and total

deduction of P2,825,974.98 which is in contrast with Section 3 of COA Circular No.

96-011. Also, the lack of proper action on a reconciling item that is to be adjusted by

the bank totaling P221,749.38 further casts doubts on the reconciliation process. 2. The accuracy, correctness and fair presentation of the Property, Plant and Equipment

(PPE) account, totaling P 221,523,388.97, could not be ascertained, due to the

misclassification of accounts, inclusion of inventory items, expense and other

accounts which could not be classified as PPE, in contrast with Section 121 of PD

1445.

3. Accounts Payable and Other Payable accounts totaling P2,648,893.09 and

P4,043,871.39, respectively, cannot be relied upon due to absence of schedules to

support valid claims, in violation of the 1987 Administrative Code and Section 70 of

Manual on New Government Accounting System (NGAS).

4. Property, Plant and Equipment totaling P7,625,726.63 was dropped from the books of

accounts without the application of procedures prescribed in the Guidelines on

Disposal and the submission of the required documents resulting to the reduction of

the asset account by the said amount, thereby affecting the reliability of the financial

statements.

5. Disbursements for livelihood projects was included in the property, plant and

equipment account overstating the said account by P 902,642.10.

6. Appropriation for Personal Services (PS) for the CY 2015 exceeded the 45%

limitation for Personal Services in the total amount of P4,766,860.42 in violation of

Section 325 (a) of R.A. 7160.

7. CY 2015 budget totaling P4,890,341.30 for the JH Cerilles State College-

Margosatubig Extension Campus was not enacted through an ordinance by the

Sangguniang Bayan as required under Section 319 of RA 7160.

8. CY 2015 Budget for Special Education Fund (SEF) was not approved by the Local

School Board contrary to Section 100, Title IV, Republic Act No. 7160.

9. Various deficiencies were noted in the procurement, disbursement, implementation

and ocular inspection of the Aquamarine Farming Project resulting to incurrence of

irregular expenditures totaling P5,000,000.00.

SUMMARY OF SIGNIFICANT OBSERVATIONS AND RECOMMENDATIONS

Presented below are the significant audit observations and recommendations

noted in the course of audit:

1. Balances of Cash – Local Treasury account in all funds amounting to P2,967,910.90 as of

December 31, 2015, were not deposited intact to the authorized depository bank in

violation of Section 32 of the Manual on the New Government Accounting System

(NGAS), thus exposing government funds to the risk of possible loss, misuse, or

misappropriation by the concerned Accountable Officer.

We recommend that the Municipal Treasurer deposit her collections intact and

regularly to avoid misuse of government funds pursuant to Section 32 of the Manual

on the New Government Accounting System.

2. Cash Advance for Intelligence Expenses totaling P245,000.00 was granted to the Local

Chief Executive even when the liquidation vouchers/reports for previous cash advances

totaling P800,000.00 were not submitted to the COA Chairman for post-audit and

issuance of credit advice as required in General Guidelines No. 6 of COA Circular No.

2003-003 resulting to the incurrence of irregular expenditure amounting P245,000.00.

We recommend that the Municipal Accountant follow the guidelines in the granting

of subsequent cash advances for confidential and intelligence expenses as provided

in COA Cir. No. 2003-003 as amended by the latest COA, DBM, DILG, GC for

GOCCs and DND Joint Memorandum Circular No. 2015-01 dated January 8, 2015.

3. Advances granted to Special Disbursing Officers and Officers and Employees amounting

to P15,897,554.87 and P4,066,238.94, respectively remained unliquidated as of

December 31, 2015 in violation of Section 89 of P.D. 1445 and Section 5.8 of COA

Circular No. 97-002, thereby exposing the accountable officer to the penalties for its non-

liquidation.

We recommend that management (1) Demand the concerned officials and

employees with unliquidated cash advances to effect immediate settlement of cash

advances, otherwise, the necessary sanction for its settlement as provided for in

paragraph 9.1 of COA Circular No. 2012-004 dated November 28, 2012 shall be

enforced; and (2) Enforce full liquidation of cash advances within the reglementary

period provided under COA Circular No.97-002 dated February 10, 1997.

4. Cash advances totaling P 2,951,118.24 were granted even when the claims lack

supporting documents contrary to Paragraph 6, Section 4 of PD 1445. Further, cash

advances totaling P 215,353.98 were granted for the payment of various expenditures

which were previously paid from the collection of the Municipal Treasurer contrary to

Sec. 172 (b) of Government Accounting and Auditing Manual (GAAM), Volume 1.

We recommend that the Municipal Accountant examine the completeness of the

supporting documents to ensure validity, propriety and legality of the transactions

and avoid suspension of disbursements in audit.

5. Cash advances by the Local Chief Executive (LCE) for travelling expenses during the

year totaling P452,500.00 were not in accordance with the guidelines set forth in Section

4 of Executive Order (EO) No. 298 and Sec. 96 of RA 7160.

We recommend that the Municipal Mayor follow the guidelines on travel under EO

No. 298 and the Municipal Accountant to examine the completeness of the

supporting documents to avoid suspension/disallowance of disbursements in audit.

6. Representation Allowance and Transportation Allowance (RATA) granted in full despite

having incurred absences and/or leaves that are not construed as actual work performance

in violation of Section 7 DBM Local Budget Circular No. 103, May 15, 2013.


supporting documents for every transaction of the municipality before payment

shall be done to avoid possible suspensions and/or disallowances in audit and to

strictly comply with the requisites as provided in DBM Local Budget Circular No.

103 dated May 15, 2013.

7. Personnel Economic Relief Allowance (PERA) was granted in full despite not been

supported with approved leave of absences in violation of Section 5.4 DBM Budget

Circular No. 2009-3, August 18, 2009.




strictly comply with the requisites as provided in DBM Budget Circular No. 2009-3

dated August 18, 2009.

8. Magna Carta benefits of Public Health Workers (PHW) were granted in lump-sum under

the term “Magna Carta” without regard to the rules as to the amount of specific benefits

provided by law in violation of DBM-DOH Joint Circular No. 1, s2012 dated November

29, 2012, thus expenditures for each Magna Carta benefit cannot be identified.


supporting documents for every transactions of the municipality before payment


strictly comply with the requisites as provided in DBM-DOH Joint Circular No. 1,

s2012 dated November 29, 2012, pursuant to Republic Act No 7305 entitled as

“Magna Carta of Public Health Workers”.

9. Overtime pay granted to employees and Public Health Workers (PHW) was not in

accordance with the rules and regulations provided in DBM Budget Circular No. 10 dated

March 29, 1996 and Section 5.10 of COA Circular No. 2012-001 dated June 14, 2012,

thereby affecting the validity, propriety, legality of the expenditures.

We recommend that the Municipality comply with the rules and regulations in

DBM Budget Circular No. 10 dated March 29, 1996, as repealed by CSC-DBM Joint

Circular No. 1 s.2015 dated November 25, 2015, and Section 5.10 of COA Circular

No. 2012-001 dated June 14, 2012, to ensure validity, propriety and legality of the

disbursements. In addition, the municipality shall strictly comply with the rules and

regulations espoused in Item a, Section 138 Government Accounting and Auditing

Manual (GAAM) and refrain from disbursing government fund without an

appropriation, law or other specific statutory authority.

10. Appropriations for the 20% of the Internal Revenue Allotment (IRA) was not optimally

utilized due to the unutilized amount of P7,877,382.16 contrary to Item 5.0 of DILG and

DBM Joint Circular No. 2011-1, thus, the desirable socio-economic development and

environmental outcomes are not attained.

We recommend that appropriation for 20% EDF be optimally utilized, thus, the

local chief executive shall ensure compliance with the responsibilities provided for in

paragraph 5.0 of DILG and DBM Joint Circular No. 2011-1 to achieve desirable

socio-economic development and environmental outcomes. Further, the Municipal

Planning and Development Coordinator and the Municipal Development Council

shall properly formulate the annual public investment programs by properly

identifying PPAs and monitor the implementation of the projects as incorporated in

the Annual Investment Plan.

11. Maintenance and Other Operating Expenses and Capital Outlay totaling P16,290.00 and

P171,444.61, respectively intended for the office use of the LDRMO were charged to

Local Disaster Risk Reduction and Management Fund (LDRRMF) which are not

consistent to the policy guidelines provided under Item 4.0 of NDRRMC,DILG,DBM

and CSC Joint Memorandum Circular No. 2014-1, thereby, reducing the funds intended

to support disaster risk management activities.

We recommend that appropriations for MOOE and CO for the Office of the

MDRRM be included in the annual budget of the local government to provide

sufficient funds for the DRRM programs.

12. Government Funds were disbursed even if the claims lacked the necessary supporting

documents contrary to Paragraph 6, Section 4 of Presidential Decree No. 1445 and COA

Circular No. 2012-001 dated June 14, 2012, thus validity, propriety and legality of the

expenditures totaling P 3,623,297.59, cannot be ascertained.

We recommend that municipal officials involved in the approval and payment of the

transactions examine the completeness of the supporting documents to ensure their

validity, propriety and legality and avoid suspension of disbursements in audit.

13. Job Order Employees are being hired to perform functions which pertain to the job

description for vacant regular plantilla position in violation of Section 4(c) of CSC

Memorandum Circular No. 17-02 dated June 24, 2002 adopting Resolution No. 02-0790

dated June 5, 2002.

We recommend that the Municipality comply with the rules and regulations on the

contract of services, particularly stipulations made in the Job Orders/ Appointments

to comply with the Civil Service Commission Resolution No. 020790 dated June 5,

2002, to ensure validity, propriety and legality of the disbursements.

14. Purchase of tires totaling P136,487.87 and Repair of government vehicle totaling

P236,179.30 were found excessive as defined under Section 5 of COA circular No. 2012-

003 dated October 29, 2012, thus, draining the funds and resources of the Municipality

which could be utilized to support the developmental projects due to the constituents.

We recommend that the municipal government refrain from disbursing excessive

disbursements as defined under Section 5 of COA circular No. 2012-003 to avoid

disallowance. Also, the Municipal Accountant examines the completeness of the

supporting documents relative to the payment of tires and repair of government

vehicle to ensure validity, propriety and legality of the transactions.

15. Mode of transportation used by officials/employees for travel claims totaling P63,900.00

was not in accordance with the provisions of Sec. 340 of Government Accounting and

Auditing Manual (GAAM) thus exposing government funds to misuse resulting to

irregular expenditures.

We recommend that officials and/or employees adhere to the provisions of Section

340 of GAAM when having official travel to promote economy in the usage of the

scarce resources of the municipal government.

16. Financial assistance totaling P58,000.00 was granted to support the activities of the

various organizations which are not within the mandate of the local government unit as

provided in Section 17 of RA 7160 and contrary to COA Circular No. 2012-003 dated

October 29, 2012, resulting to the incurrence of irregular expenditures.

Management refrain from granting financial assistance to support the activities of

the various organizations which are not falling within the mandate of the municipal

government.

17. Financial Assistance to the Sangguniang Bayan (SB) Members to defray expenses during

the 79th Araw ng Margosatubig was granted in excess of the requested budget as per SB

Resolution No. 2015-66 and even when the claims lacked the necessary supporting

documents contrary to Paragraph 6, Section 4 of Presidential Decree No. 1445, thereby

validity, propriety and legality of the expenditures totaling P200,000.00, cannot be

reasonably ascertained.


transactions examine the completeness of the supporting documents and refrain

from granting claims in excess of the estimated budget/budgetary requirements to

ensure validity, propriety and legality of the disbursements. Further, the Municipal

Accountant shall prepare an adjusting entry to reclassify the expense from financial

assistance to Cash Advance of the respective Sangguniang Bayan Members.

18. Guidelines in the pre-selection procedure in the conduct of limited source bidding for the

procurement of biodegradable shredder machine totaling P450,000.00 were not followed

by the BAC as required in GPPB Resolution 05-2011, thereby, the most advantageous

price in favor of the municipal government was not availed. In addition, warranty

security was not imposed to ensure that manufacturing defects be corrected by the

supplier.

We recommend that the BAC follow the guidelines as provided in Appendix 26 of

the Handbook on Philippine Government Procurement Sixth Edition relative to the

Pre-Selection Procedure in the Conduct of Limited Source Bidding to avail the most

advantageous price in favor of the municipal government. In addition, warranty

security be imposed to ensure that manufacturing defects be corrected by the

supplier.

19. Guidelines for Shopping and Small Value Procurement in the procurement of catering

services (meals and snacks) totaling P687,135.95 and construction and electrical

materials totaling P156,960.00 were not followed by the BAC as required in GPPB

Resolution 09-2009, thereby, the most advantageous price in favor of the municipal

government was not availed.


the Handbook on Philippine Government Procurement Sixth Edition relative to

Shopping and Small Value Procurement to avail the most advantageous price in

favor of the municipal government. In addition, Municipal Accountant to examine

completeness of supporting documents for every transaction of the municipality

before payment shall be done to ensure validity, propriety and legality of the

disbursements.

20. Small Value Procurement thru splitting of contracts was used in the procurement of

school supplies totaling P111,888.00 which is strictly prohibited as stated in Appendix 18

of the Handbook on Philippine Government Procurement Sixth Edition based on GPPB

Resolution 09-2009, thereby, the most advantageous price in favor of the municipal

government was not availed resulting to incurrence of illegal expenditures.


the Handbook on Philippine Government Procurement Sixth Edition relative to

Shopping and Small Value Procurement to avail the most advantageous price in

favor of the municipal government. In addition, Municipal Accountant to examine

completeness of supporting documents for every transaction of the municipality

before payment shall be done to ensure validity, propriety and legality of the

disbursements. Lastly, record the purchases of school supplies held for distribution

as inventory and the corresponding specific expense account be recorded upon

issuance, transfers or other disposal.

21. Procurement of fireworks for use in the 79th Araw ng Margosatubig amounting to

P192,000.00 through Direct Contracting was not in accordance with the conditions set

under Section 50 and 54.6 of the Revised IRR of RA No. 9184 and 9.2.2 of COA

Circular No. 2012-001 dated June 14, 2012, thus the validity, propriety and legality of the

expenditure is rendered doubtful.


transactions examine completeness of the supporting documents and that the Bids

and Awards Committee (BAC) strictly comply with the conditions for the use of the

Alternative Mode of Procurement provided under Revised IRR of Republic Act No.

9184 in the procurement of supplies and materials, to ensure validity, propriety and

legality of the disbursements.

22. Fund transfers to People’s Organization namely the Women Empowerment Movement

Rural Improvement Council (WEMRIC) were not in accordance with the rules and

regulations provided in COA Circular No. 2007-001 dated October 25, 2007 and Item

No. 2.1 of COA Circular No. 2012-001 dated June 14, 2012, thereby affecting the

validity, propriety, legality of the expenditures totaling P340,000.00.

We recommend that the Municipal Accountant examine completeness of the


shall be done and to strictly comply with the requisites as provided in COA Circular

No. 2007-001 dated October 25, 2007 and Item No. 2, COA Circular 2012-001 dated

June 14, 2012, to ensure validity, propriety and legality of the disbursements on

fund transfers to NGOs/POs.

23. Salaries and wages of Officials and Employees were paid below the Three Thousand

Pesos (P3,000.00) net take home pay in violation of the mandate of Section 48, General

Provisions, Republic Act No. 10651, the General Appropriations Act (GAA) for the

Fiscal Year (FY) 2015.


employee’s monthly net take home pay, particularly stipulations made in the

General Provisions of the General Appropriations Act for FY 2015 that the same

shall in no case be lower than Three Thousand Pesos (P3,000.00) to ensure validity,

propriety and legality of the disbursements.

24. Salaries and wages of Casuals under Job Order/ Appointments were paid on a monthly

basis and even when the claims lacked the necessary supporting documents contrary to

Civil Service Commission Resolution No. 020790 dated June 5, 2002 COA Circular No.

2012-001 dated June 14, 2012, thereby validity, propriety and legality of the

expenditures totaling P 419,462.47, cannot be reasonably ascertained.


contract of services, particularly stipulations made in the Job Orders/ Appointments

to comply with the Civil Service Commission Resolution No. 020790 dated June 5,

2002 and COA Circular 2012-001 dated June 14, 2012, to ensure validity, propriety

and legality of the disbursements.

25. Various offices of LGU-Margosatubig did not prepare their respective Project

Procurement Management Plan (PPMP) for their different programs, activities and

projects (PAPs) as required under Section 7.3.2 of Rule II of the Revised Implementing

Rules and Regulations (IRR) of RA 9184 resulting to non-preparation of the required

Annual Procurement Plan (APP).

It is recommended that the Heads of the various offices of LGU-Margosatubig to

prepare their respective PPMPs and submit to the Municipal Budget Office for

review and be included in budget proposal for CY 2016 subject for the approval of

the local chief executive. Upon approval, the said documents should be submitted to

the BAC Secretariat for consolidation into the proposed Annual Procurement Plan.

26. Non-issuance of Acknowledgment Receipts for Equipment (ARE) for all non-expendable

equipment totaling P886,207.04 which were issued to the end-users is contrary to Section

492, GAAM Vol. I and Section 23 of Manual on NGAS-Local, thereby weakens the

internal control on the property and supply management system.

We recommend that the Property Officer issue ARE for all equipment issued for the

official use of officials and employees. Also, the Municipal Accountant require

submission of ARE before payment be made for all non-expendable property and

equipment as required under COA Circular No. 2012-001.

27. Delinquent Real Property Taxes amounting to P4,378,667.41 were not collected due to

inability of the Municipal Officials concerned to initiate remedies and measures

prescribed under Section 254 and 258 of R 7160. As such, the municipality was deprived

of additional income needed for the delivery of basic services to the constituents.

We recommend the municipal treasurer enforce the remedies and measures

prescribed under Section 254 and 258 of RA 7160 to collect delinquent real property

taxes. Strengthen collection system through intensified tax campaign to eliminate

and/or minimize delinquencies.

28. Funds withheld for the BIR, GSIS, PAG-ibig and PhilHealth amounting to

P2,416,472.11, P1,389,734.40, P12,595.84 and P108,685.17, respectively, were not

remitted on time which may cause forfeiture of claims/benefits due the

member/employees of the municipality and deprived the agencies concerned of the

timely use of said funds.

We recommend that the Municipal Accountant and the Municipal Treasurer

facilitate the immediate remittance of withholding taxes and contributions

particularly those pertaining to prior years due to BIR, GSIS, Pag-IBIG and

Philhealth within the prescribed period to enable these agencies to use the needed

funds for its operations in a timely manner and to preclude delay in the processing

of members/ employees’ claims and prevent possible forfeiture of the benefits due

them to protect their interest.

29. The Municipality maintained a bank Account with Philippine National Bank which is not

an Authorized Government Depository Bank (AGDB) as defined under DOF Cir. No.

001-2015 dated June 1, 2015.

We recommend that the municipality close the PNB current account no. 3351-7940-

0017 and open a bank account with an Authorized Government Depository Bank in

compliance with DOF Cir. No. 001-2015.

SUMMARY OF TOTAL SUSPENSIONS, DISALLOWANCES AND CHARGES

AS OF YEAR-END

The reported audit suspensions, disallowances, and charges of the LGU as of

December 31, 2015 were as follows:

Beginning

Balance

01.01.2015

Issued This

Period

(1/1/15 to

12/31/15)

Settled

This Period

(1/1/15 to

12/31/15)

Ending

Balance

12.31.2015

Notice of Suspension 0.00 4,109,150.01 0.00 4,109,150.01

Notice of

Disallowance

326,140.30 3,538,171.37 0.00 3,864,311.67

Notice of Charge 0.00 0.00 0.00 0.00

Total 326,140.30 7,647,321.38 0.00 7,973,461.68

This does not include disallowances, suspensions and charges prior to the

effectivity of the new Rules and Regulations on Settlement of Accounts under COA

Circular No. 2009-006 dated September 15, 2009.

STATUS OF IMPLEMENTATION OF PRIOR YEARS’ AUDIT

RECOMMENDATIONS

Out of the forty-nine (49) audit recommendations in the prior years’ Annual Audit

Reports, twenty (20) were fully implemented during the year, fifteen (15) were partially

implemented and fourteen (14) were not implemented.

Documents

EXECUTIVE SUMMARY INTRODUCTION - coa.gov.ph · MOOE CO 20% EDF 5% LDRRMF ... School Board contrary to Section 100, ... Chief Executive even when the liquidation vouchers/reports for