In re: Resolution Granting Automatic Permanent Total Disability Benefits
REITERATIONFacts
The Antecedents: This administrative matter arose when the Department of Budget and Management (DBM) disallowed the 5-year lump sum gratuity claims filed by the heirs of the late Judge Melvyn U. Calvan and Judge Emmanuel R. Real. The claims were based on the Supreme Court's Resolution dated September 30, 2003, in A.M. No. 02-12-01-SC, which granted permanent total disability benefits to the heirs of Justices and Judges who die in actual service, regardless of the cause of death (except suicide). The DBM, through Undersecretary Mario L. Relampagos, argued that Section 2 of Republic Act No. 910 (R.A. 910) treats 'death while in actual service' and 'retirement due to permanent physical disability' as distinct circumstances, and that the Court's resolution expanded the law's intent. Procedural History: The Supreme Court had previously approved the applications for benefits for both judges (A.M. No. 11445-Ret for Calvan and A.M. No. 10821-Ret for Real). Following these approvals, the Fiscal Management and Budget Office (FMBO) of the Court requested the DBM to issue Special Allotment Release Orders (SARO) to cover the payments. The DBM denied these requests, prompting the Court to address the DBM's refusal to release the funds. The Petition: This is an internal administrative resolution of the Supreme Court acting on the DBM's refusal to honor the Court's prior directives. The Court addressed whether the DBM, an executive agency, has the authority to review and override the Supreme Court's interpretation of R.A. 910 and its exercise of fiscal autonomy.
Issue(s)
Whether the Department of Budget and Management (DBM) has the authority to disallow the release of funds by substituting its own interpretation of Republic Act No. 910 for that of the Supreme Court.
Ruling
The Supreme Court RESOLVES to DIRECT the Department of Budget and Management (DBM) to: (a) release the amounts corresponding to the permanent total disability benefits to the heirs of the late Judges Melvyn U. Calvan and Emmanuel R. Real within ten (10) days from notice, and (b) implement the Resolution dated September 30, 2003, in A.M. No. 02-12-01-SC in all cases of death of Justices and Judges while in actual service.
Ratio Decidendi
On the Issue of DBM's Authority to Interpret Law: The Court held that the DBM has no authority to construe the law in a manner that overrides the Judiciary's interpretation. Under the principle of separation of powers, as elucidated in United States v. Ang Tang Ho, it is the exclusive duty of the Judiciary to construe the law, and the Court's construction is final. The Court emphasized that its Resolution dated September 30, 2003, was issued pursuant to its constitutional mandates of fiscal autonomy and administrative supervision over all courts. By refusing to release the funds, the DBM engaged in a 'blatant usurpation of an exclusively judicial function.' The Court further noted that judicial decisions, per Article 8 of the New Civil Code and People v. Jabinal, form part of the legal system and the statute they interpret as of the date of the statute's enactment. Finally, the Court reiterated that while the DBM has the responsibility to ensure disbursements are made according to law, this does not include the power of judicial review over the Supreme Court's issuances.
Main Doctrine
The Supreme Court's construction of a law is final and becomes an integral part of the statute itself. Pursuant to the mandates of fiscal autonomy and administrative supervision, the Court possesses the authority to fill gaps in legislation (such as Republic Act No. 910) to prevent injustice. Once the Court has issued a resolution interpreting a law, executive agencies like the Department of Budget and Management (DBM) have no power of judicial review and must implement the Court's directives, as any refusal constitutes a violation of the separation of powers.