Facts:

The case involves Quirico D. AniAon (Petitioner) and the Government Service Insurance System (GSIS) (Respondent). The events leading to the case began with AniAon's intermittent government service from 1969 to 1982, during which he worked for various government agencies, including the Bureau of Census and Statistics, the Department of Justice, and the Supreme Court. After a hiatus, he returned to the civil service in 1988 as an employee of the Supreme Court but resigned in 1989 to work abroad. At the time of his resignation, the applicable retirement law was Presidential Decree No. 1146, which required at least 15 years of service for retirement benefits. AniAon had only 12 years of service and thus was not eligible for retirement benefits. Upon his voluntary separation, he received a refund of his premiums amounting to P16,345.12.

AniAon was reinstated in the civil service on August 19, 1996, and subsequently transferred to the Professional Regulatory Commission, the C...

Facts:

Employment and Service History of the Petitioner

• Quirico D. AniAon rendered intermittent government service from 1969 until 1982.
• Initially employed at the Bureau of Census and Statistics.
• Later served at the Department of Justice and subsequently at the Supreme Court.
• In 1988, AniAon resumed his civil service career as an employee of the Supreme Court.
• In 1989, he voluntarily separated from the civil service to work abroad.
• At the time of separation, AniAon had accumulated only 12 years of service, which was below the 15-year minimum requirement for retirement benefits under the prevailing law.
• He received from the Government Service Insurance System (GSIS) an amount of ₱16,345.12 representing the refund of his premiums, pursuant to Section 11(d) of Commonwealth Act No. 186 as amended by Republic Act No. 660.

Relevant Retirement Laws and Their Application

• Prior to 1997, the retirement benefit law was governed by Presidential Decree No. 1146, which mandated a minimum of 15 years of service for full retirement benefits.
• Subsequent to his separation, AniAon was not entitled to full retirement benefits since his service was both intermittent and insufficient in duration.
• In 1997, Republic Act No. 8291 (GSIS Act of 1997) came into effect, amending the guidelines for retirement eligibility, including:
• The rule that, for reinstated employees, the computation of total service would include periods of service rendered with different employers but would exclude years for which retirement benefits had already been paid.
• The clarification that a reinstated employee is treated as a “new entrant” for purposes of computing benefits if he previously received retirement benefits.

Reinstatement and Subsequent Developments

• On August 19, 1996, AniAon was reinstated into the civil service as an employee of the Professional Regulatory Commission.
• He was later transferred to the Court of Appeals on June 3, 1998, and finally to the Supreme Court on January 19, 2001, where he continued until February 28, 2008.
• With his reinstatement, AniAon sought to have his prior government service of 12 years credited toward his future retirement benefits.

GSIS Policy and the Refund Requirement

• In 2006, the GSIS issued Policy and Procedural Guidelines (PPG) No. 183-06, which:
• Mandated that reinstated employees who wished to claim full credit for previous service must refund the retirement benefits previously received.
• Imposed a strict 30-day period for the refund, as counted from the publication date of the policy in newspapers of general circulation.
• The GSIS opinion and subsequent confirmation by the Department of Justice (DOJ Opinion No. 106) addressed common queries regarding:
• The inclusion of previous service when retirement benefits previously received had been refunded.
• The sufficiency of publication as notice for new policy guidelines.

Petitioner’s Requests and GSIS Response

• In a letter dated November 20, 2006, AniAon informed GSIS of his intention to retire on his 63rd birthday (March 24, 2007) and requested that:
• His 12-year prior government service be credited for the purpose of calculating retirement benefits.
• He be exempt from the strict refund requirement of PPG No. 183-06, or alternatively, that the amount of his refunded premiums be offset against future retirement proceeds.
• Mr. Robert M. Agustin, Vice President, Social Insurance Operations Office I of the GSIS, denied AniAon’s request in a consequent letter dated January 24, 2007.
• AniAon escalated his petition to the GSIS Board of Trustees and later filed an appeal through the Court of Appeals (CA).

Proceedings in the Lower Courts

• The GSIS Board of Trustees dismissed AniAon’s petition in their decision on December 12, 2007.
• The Board reasoned that the publication of PPG No. 183-06 in newspapers satisfied the due process requirement.
• It held that personal service of notice was not mandated by law.
• It further ruled that equal treatment under the guidelines was maintained since all similarly situated members had to comply with the same 30-day refund deadline.
• The CA, in its decision rendered on August 7, 2009, affirmed the decision of the GSIS Board of Trustees and denied AniAon’s plea to be exempt from the refund requirement.
• AniAon subsequently moved for reconsideration at the CA level, which was denied, prompting his appeal to the Supreme Court.

Issue:

• Whether the publication of PPG No. 183-06 in newspapers of general circulation, without personal notice to each member, met the constitutional requirement of due process.
• Whether PPG No. 183-06 impaired any of AniAon’s vested rights or interests in relation to his retirement benefits.
• Whether the imposition of the refund requirement (or its strict deadline) violated AniAon’s right to equal protection under the law.
• Whether AniAon, as a reinstated employee who had previously received a refund in 1989, should be exempted from the refund requirement or allowed to have such refund amount offset against future retirement proceeds.
• Whether AniAon had already vested his right to retirement benefits by virtue of his previous separation and the benefits (refund of premiums) received under the earlier applicable law (R.A. No. 1616).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)