G.R. No. 246451 - Leonardo vs. People

Petitioner, Leonardo Alcantara, has been in government service since November 4, 1939, working in the Office of the Register of Deeds of Batangas.
He was designated as the Deputy Register of Deeds effective July 1, 1960, earning an annual salary of P6,798.00.
Petitioner is classified as a second grade and special deputy assessor eligible, which under normal civil service rules commands a maximum salary of P7,200.00 per annum.

Republic Act No. 3674, effective June 22, 1963, amended section 192 (b) of the Revised Administrative Code.

It mandated that the salary rates for Registers of Deeds (excluding those in the City of Manila) be subject to revision not more than once every three years by the Secretary of Justice.
The readjustments were to be based on the “yearly average collections for the last three years immediately preceding the year in which the revision is made.”
Critically, it provided that the salary of a Register of Deeds and that of his Deputy “shall not be lower than those of the lowest department head and assistant department head of the corresponding province or city by more than one thousand two hundred pesos per annum.”

The passage of Republic Act No. 4477 classified Batangas as a first class province based on income, triggering a readjustment under Administrative Order No. 215 issued by the Secretary of Justice on May 28, 1969.

Under this Administrative Order, effective June 1, 1969, the salary of a Deputy Register of Deeds was set at P12,000.00 per annum.

Despite the administrative order adjusting petitioner’s salary to P12,000.00, the respondent Commissioner of Land Registration notified petitioner via letter on June 1, 1969, that his salary would instead be limited to P7,200.00 per annum, resonating with the salary limit prescribed for second grade eligibles under Section 9 of the Civil Service Law (Republic Act No. 2260, as amended by R.A. 4380).
The case was then referred to the Secretary of Justice, whose Opinion dated July 25, 1969, maintained that petitioner was not entitled to a salary exceeding the maximum civil service rate for his eligibility level.

The explanatory note accompanying House Bill No. 1941 highlighted the intent to mitigate discrimination against registers of deeds by acknowledging their increased workload and revenue collections, which had significantly increased over the years.
The directive sought to lessen the discrepancy between the salaries of the Register and his immediate deputies by updating their remuneration to reflect current economic realities.
In response to petitioner’s submission, the Director of Classification and Compensation of the Wage and Classification Office (WAPCO) indicated in his 1st Indorsement (dated July 31, 1969) that the position of Deputy Register of Deeds is exempt from the regular classification and pay plans applicable to civil service positions as per Section 9 of R.A. No. 2260.

Whether the salary of the petitioner, Leonardo Alcantara, as Deputy Register of Deeds of Batangas, may be adjusted to P12,000.00 per annum pursuant to Republic Act No. 3674 and Administrative Order No. 215.

The central issue involves reconciling the statutory mandate for salary adjustment under R.A. No. 3674 with the limitation set by Section 9 of Republic Act No. 2260 (as amended), which caps the maximum salary for a second grade eligible at P7,200.00 per annum.
Whether the legislative intent behind R.A. No. 3674 and subsequent administrative adjustments exempts the post of Deputy Register of Deeds from the salary restrictions imposed by WAPCO’s classification scheme.

The extent of the application of Section 9 of the Civil Service Law to positions affected by special legislative measures.

The issue questions if the salary ceiling, applicable to grouped civil service positions, continues to bind a position that has been expressly adjusted by a special administrative order and legislative provision.
Whether the exemption provided by the Director of Classification and Compensation, stating the position’s exemption from classification standards, adequately overrides the prescribed salary cap.