Mecano v. Commission on Audit
REITERATIONFacts
The Antecedents: Petitioner Antonio A. Mecano, a Director II of the National Bureau of Investigation (NBI), was hospitalized for cholecystitis from March 26, 1990, to April 7, 1990. He incurred medical and hospitalization expenses totaling P40,831.00 and sought reimbursement under Section 699 of the Revised Administrative Code (RAC). Procedural History: Petitioner's claim was initially recommended for favorable action by NBI Director Alfredo S. Lim and the Committee on Physical Examination of the Department of Justice, finding his illness service-connected. However, the claim was returned by the Undersecretary of Justice, citing the Commission on Audit's (COA) position that Section 699 of the RAC was repealed by the Administrative Code of 1987. Petitioner re-submitted his claim, supported by an opinion from the Secretary of Justice stating that Section 699 was not repealed. The claim was again forwarded to the COA, which ultimately denied it in its 7th Indorsement, dated January 16, 1992, on the sole ground that Section 699 was repealed by the Administrative Code of 1987. The COA suggested filing the claim with the Employees' Compensation Commission. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, seeking to nullify the COA's decision. The core issue presented to the Court was whether the Administrative Code of 1987 repealed or abrogated Section 699 of the RAC. Petitioner argued that Section 699 remained in effect and that even if a claim were filed with the Employees' Compensation Commission, it would not bar a claim under Section 699. The COA maintained that the Administrative Code of 1987, by its nature and intent, repealed the entire RAC, and that employment-related sickness was adequately covered by the Employees' Compensation Program, making simultaneous recovery unjust.
Issue(s)
Whether Section 699 of the Revised Administrative Code (RAC) was repealed by the Administrative Code of 1987. Whether petitioner is entitled to reimbursement for his medical and hospitalization expenses under Section 699 of the RAC.
Ruling
The Supreme Court resolved to GRANT the petition, ordering the respondent Commission on Audit to give due course to petitioner's claim for benefits. No costs were awarded.
Ratio Decidendi
On Whether Section 699 of the Revised Administrative Code (RAC) was repealed by the Administrative Code of 1987: The Court held that the Administrative Code of 1987 did not repeal Section 699 of the RAC by implication. Repeals by implication are not favored and require a clear and manifest legislative intent to abrogate prior laws. The repealing clause of the Administrative Code of 1987, stating that "All laws, decrees, orders, rules and regulations, or portions thereof, inconsistent with this Code are hereby repealed or modified accordingly," is a general repealing provision, not an express one. Such a clause predicates repeal on the condition of substantial conflict. The Court found that the new Code does not cover the entire subject matter of the old Code, citing several provisions in the RAC not found in the 1987 Code. Furthermore, the COA failed to demonstrate an irreconcilable conflict between the two codes on the matter of sickness benefits. The omission of Section 699 from the 1987 Code does not automatically mean repeal, especially when the new code is not intended as a complete substitute for the old one. The Court emphasized that the fact that a later enactment relates to the same subject matter is not sufficient for implied repeal; there must be a manifest indication of legislative purpose to repeal. The Court also noted that opinions of the Secretary of Justice are material in the construction of statutes in pari materia. On Whether petitioner is entitled to reimbursement for his medical and hospitalization expenses under Section 699 of the RAC: Given the Court's ruling that Section 699 of the RAC was not repealed, the petitioner's claim for reimbursement under this provision is valid. The Court found that the petitioner's illness was service-connected, as supported by the recommendations from the NBI and the Department of Justice. The Court also addressed the COA's contention that recovery under Section 699 would bar recovery under the Employees' Compensation Program. The Court clarified that Article 173 of the Labor Code, as amended by P.D. 1921, expressly provides that payment of compensation under Title II of Book IV of the Labor Code shall not bar the recovery of benefits as provided for in Section 699 of the RAC. Therefore, the petitioner is entitled to pursue his claim under Section 699.
Main Doctrine
The enactment of the Administrative Code of 1987 did not repeal Section 699 of the Revised Administrative Code (RAC) by implication. Repeals by implication are disfavored and require a clear legislative intent to abrogate prior laws. The general repealing clause in the Administrative Code of 1987 only repeals inconsistent laws, and the omission of Section 699 from the new Code does not effect a repeal because the new Code does not cover the entire subject matter of the RAC and was not clearly intended as a substitute. Moreover, recovery under Section 699 is not barred by the Employees' Compensation Program.