The transaction was deemed irregular by COA, Del Campo said, and formed part of a notice of disallowance issued against the OVP.
“Hindi ito pwedeng i-transfer from one accountable to another,” Del Campo told the Senate impeachment court.
Del Campo said the transaction violated Joint Circular No. 2015-01, which sets the rules for the release, use, reporting and audit of confidential and intelligence funds.
The circular requires, among other things, that cash advances for confidential and intelligence funds be granted to designated special disbursing officers and supported by documents including their designation and approved fidelity bond.
The auditor explained that the special disbursing officer, or SDO, was responsible for disbursing the cash advance, while the agency head’s responsibility was to oversee the use of confidential funds.
“It is the SDO na mag-dedisperse ng cash advance,” Del Campo said.
The agency head, she added, had the responsibility “to oversee” the agency-wide use of confidential funds.
She identified Duterte, Acosta, OVP Chief Accountant Julieta Villadelrey and Lachica as responsible persons in a March 31, 2026 notice of disallowance issued by COA’s intelligence and confidential funds audit office.
Duterte was considered accountable because she approved the transactions and the use of the cash advances, Del Campo said. Her approval was reflected in accomplishment reports.
“Because she approved po the transactions and the utilization of the cash advance po,” Del Campo said.
Acosta was also held accountable because she was the designated SDO and was responsible for disbursing the cash advance.
Asked to explain what “accountable” meant, Del Campo said it referred to the person who had responsibility for public funds entrusted to them.
“Yung taong may pananagutan po sa pondo na binigay sa kanya,” she said.