ACKNOWLEDGMENT receipts are deemed acceptable as supporting documentary evidence for the spending of confidential funds, Commission on Audit’s Intelligence and Confidential Funds Audit Office (ICFAO) auditor Xylene del Campo said on Wednesday, August 12, 2026.
During the resumption of the impeachment trial of Vice President Sara Duterte, defense counsel Kristine Ferrer confronted Del Campo with Section 34(A)(1)(b) of the National Internal Revenue Code (NIRC), which mandates that “no deduction from gross income shall be allowed under Subsection (A) hereof unless the taxpayer shall substantiate with sufficient evidence, such as official receipts or other adequate records: (1) the amount of the expense being deducted, and (ii) the direct connection or relation of the expense being deducted to the development, management, operation and/or conduct of the trade, business or profession of the taxpayer.”
Private prosecutor for the House of Representatives Lorna Kapunan objected to Ferrer’s inquiry, saying it was “immaterial and irrelevant beyond the scope.”
“This is the National Internal Revenue Code for taxpayers. What is relevant here is the payment of taxes, what is allowed as deductions, and what documents are allowed to substantiate findings here. It refers to gross income, Your Honor. What does gross income have to do with the confidential funds of the Office of the Vice President and the DepEd (Department of Education)?” Kapunan said.
Due to time constraints, impeachment trial presiding officer Francis “Chiz” Escudero asked Del Campo about the applicability of the NIRC provision to the COA, particularly whether acknowledgment receipts are acceptable in the liquidation of confidential funds apart from official receipts.
“Aplikable (applicable) din ba ang ‘adequate records’ maliban sa resibo sa COA at hindi lamang sa NIRC bilang accountant?” Escudero asked, to which Del Campo responded in the affirmative.
The witness said acknowledgment and reimbursement receipts are among the evidentiary documents submitted by national government agencies in the liquidation of their confidential funds.
“Pwede bang gamiting ang ‘adequate records’ sa pagbili ng bagay-bagay? Table, chairs, pwedeng ‘adequate records’ at hindi kailangan official receipts sa lahat ng panahon? Depende sa kalagayan at sitwasyon,” Escudero said.
“Pero kasi ito po ay nagpepertain sa purchases, so mas sufficient po sa amin kung maipapakita ang sales invoice or official records po. Resibo lang po talaga para mapatunayan na binili ’yon para sa tables and chairs,” Del Campo responded.
For the purchase of information or payment of rewards, acknowledgment receipts are sufficient as they are considered “adequate records.”
Another witness, Roderick Wamil, a former COA-ICFAO auditor, earlier said that only the Office of the Vice President and the Department of Education (DepEd) under Duterte’s leadership submitted acknowledgment receipts as supporting evidence instead of official receipts (ORs) and sales invoices in the liquidation of confidential funds.
The OVP submitted more than 2,000 acknowledgment receipts from December 2022 through the third quarter of 2023, while DepEd submitted a total of 1,824 for the three quarters of 2023.
Under the accomplishment report submitted by the OVP to the COA-ICFO for the period of utilization of the confidential funds covering December 21 to 31, 2022, P34.857 million of the P125 million in confidential funds was spent on various goods, P24.93 million on medicines, P11.813 million on supplies, P500,000 on tables and chairs, and P3 million on desktop computers and printers.
The funds included P73 million in confidential funds that were disallowed by the COA due to insufficient supporting documentary evidence.
The disallowed spending for December 2022 included P10 million for reward payments, P34.857 million for rewards through various goods, P24.93 million for rewards through medicines, and P3.5 million for tables, chairs, desktop computers and printers.
For DepEd, the COA issued a notice of disallowance covering P375 million in expenditures after the admission made by DepEd special disbursing officer Gina Acosta in a House hearing last year that she handed over the cash to former Vice Presidential Security Protection Group head Colonel Raymund Lachica. This was a violation of the guidelines on the use of confidential funds, which state that “under no circumstance shall it be used for liquidation of the previous cash advance or be transferred from one accountable officer to another.”
Del Campo reiterated that the spending of the OVP’s confidential funds was irregular, noting that supplier details were not confidential and that receipts or invoices should have been submitted to prove supply purchases made using the funds.
“Hindi naman po confidential ‘yung mismong establishment na nag-kuwan noon. Doon po sa resibo na ’yun, hindi naman po siya confidential information,” she said.
She, however, admitted that it is within the authority of government offices to identify which information they consider “confidential.”
Del Campo also admitted that there were activities in the OVP’s Protective Intelligence Operations Report that they believed were related to surveillance and intelligence operations in the liquidation of its confidential funds.
During the cross-examination, Ferrer and Kapunan engaged in a heated argument, prompting Escudero to urge them to temper their words and not let their “generational divide” get in the way of the proceedings.
This came after Ferrer pressed Del Campo to answer whether an arrest was necessary to establish that information provided by an informant had yielded results before a reward could be paid, and whether this was a basis for determining the success of a surveillance and intelligence operation.
While she was asked to answer “yes” or “no,” Del Campo explained that under Section 4.8.5 of the joint circular on the auditing of confidential funds, payments of rewards to informers “should be supported with documents evidencing the success of the information gathering and/or surveillance activities on account of the information given by the informer.”
Kapunan objected to Ferrer’s questioning, noting the limits of cross-examination.
“Never mind if you're on cross. There are limits to cross-examination. Misleading questions are not allowed,” Kapunan said.
“They are allowed!” Ferrer countered.
This prompted Escudero to intervene, calling on both counsels to calm down.
“Counsels, please, let's not allow the generational or seeming generational divide [to] increase the tension in the courtroom. Let's keep it a notch lower,” Escudero said.
“Your Honor, please, I am preventing myself from giving her a spanking. That is what I want to do in the generational divide,” Kapunan jokingly said.
“You are all members of the bar and you are all counsels for the parties. And we will be treating and looking at each one equally,” Escudero said.
Ferrer said she had high respect for Kapunan, whom she considered one of her idols.
“Let's end here. It might sound like a eulogy, Your Honor. I'm still very much alive,” Kapunan said. (TPM/SunStar Philippines)