Endencia v. David
REITERATIONFacts
1. The Antecedents: This case concerns the constitutionality of Section 13 of Republic Act No. 590, which sought to levy income tax on the salaries of public officers, including judicial officers. The plaintiffs, Justice Pastor M. Endencia and Justice Fernando Jugo, argued that collecting income tax on their salaries constituted a diminution of their compensation, which is prohibited by the Constitution for members of the judiciary. 2. Procedural History: The Court of First Instance of Manila, relying on the Supreme Court's prior ruling in Perfecto vs. Meer, declared Section 13 of Republic Act No. 590 unconstitutional. The court ordered the Collector of Internal Revenue to refund the income taxes collected from Justices Endencia and Jugo. The Collector of Internal Revenue appealed this decision to the Supreme Court. 3. The Petition: The appeal, brought before the Supreme Court, centers on whether Congress, through legislation, can override a constitutional interpretation by the judiciary. Specifically, the appellant argues that Republic Act No. 590, particularly Section 13, authorizes the collection of income tax on judicial salaries and declares such collection not to be a diminution of compensation. The appellees maintain that this legislative act constitutes an invasion of the judiciary's exclusive power to interpret the Constitution and that the collection of income tax on judicial salaries remains a prohibited diminution of their compensation.
Issue(s)
Whether Section 13 of Republic Act No. 590, which declares that the payment of income tax on the salary of a public officer is not a diminution of his compensation, is constitutional. Whether the collection of income tax on the salaries of judicial officers constitutes a diminution of their compensation, in violation of Section 9, Article VIII of the Constitution.
Ruling
The decision of the Court of First Instance of Manila is affirmed. Section 13 of Republic Act No. 590 is declared unconstitutional insofar as it attempts to interpret the Constitution and declare that the collection of income tax on judicial salaries is not a diminution of compensation. The refund ordered by the lower court is upheld.
Ratio Decidendi
On the constitutionality of Section 13 of Republic Act No. 590: The Court held that the interpretation and application of laws, including the Constitution, belong exclusively to the Judicial department. By enacting Section 13 of Republic Act No. 590, Congress invaded the province of the Judiciary by attempting to define the meaning of the constitutional phrase "which shall not be diminished during their continuance in office." The Legislature cannot pass declaratory acts that bind the courts or usurp the judicial function of interpreting the law. Therefore, this legislative attempt to define the constitutional prohibition is void. On whether the collection of income tax on judicial salaries constitutes a diminution of compensation: The Court reiterated its ruling in Perfecto v. Meer. It found that the collection of income tax on the salary of a judicial officer is an actual and evident diminution of that salary. This is particularly evident under the withholding tax system, where the tax is deducted at source, meaning the officer never actually receives the full salary. The prohibition in Section 9, Article VIII of the Constitution against the diminution of judicial salaries is intended to preserve the independence of the Judiciary, a matter of public policy and interest, not merely a private grant to the officers. The Court emphasized that this independence is far more important than any revenue that could be derived from taxing judicial salaries.
Main Doctrine
The Legislature cannot, by statute, declare that the collection of income tax on the salary of a judicial officer is not a diminution of his compensation, as this constitutes an invasion of the judicial province of interpreting the Constitution. Such legislative declaration is void and the prohibition against diminution of judicial salaries remains in effect.