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	GR No. 202651 2013-08-28	LUCENA B. RALLOS v. CITY OF CEBU REYES, J.
This Court, in the case of University of the Philippines v. Dizon,[66] thus held that despite the existence of a final and executory judgment validating the claim against an agency or instrumentality of the Government, the settlement of the said claim is still subject to the primary jurisdiction of the COA. Ineluctably, the claimant has to first seek the COA's approval of the monetary claim.[67]