Facts:

The case titled Amelia Aquino, Rodolfo Taggueg, Jr., Adelaida Hernandez, and Leopoldo Biscocho, Jr. v. Philippine Ports Authority (G.R. No. 181973) revolves around the claims of four officials from the Philippine Ports Authority (PPA), who sought representation and transportation allowance (RATA) equivalent to 40% of their respective basic salaries. The dispute centers on various Memorandum Circulars issued by the PPA and their consonance with Republic Act (R.A.) No. 6758, also known as the Salary Standardization Law, which was enacted on August 21, 1989. The PPA had previously granted RATA to its officials, initially amounting to 40% in 1987, subsequently adjusted to 20% and then raised back to 40% effective from January 1, 1990.

In 1990, the Commission on Audit (COA) disallowed the retroactive payment of the RATA differentials, particularly for those who were appointed post the cut-off date of July 1, 1989, the date when R.A. No. 6758 took effect. Petitioners, representing sec

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Facts:

Background and Legal Framework

• The case involves the implementation of Republic Act (R.A.) No. 6758, enacted on 21 August 1989, which prescribed a revised compensation and position classification in the government, popularly known as the Salary Standardization Law.
• Prior to R.A. No. 6758, on 31 August 1979, President Ferdinand E. Marcos issued LOI No. 97, authorizing government-owned or controlled corporations (GOCCs) to implement standard compensation and position classification, particularly for the infrastructure/utilities sector.
• Based on LOI No. 97, the Philippine Ports Authority (PPA) granted its managerial and supervisory officials a representation and transportation allowance (RATA) equivalent to 40% of their basic salary through Memorandum Circular No. 57-87 dated 1 October 1987.

Evolution of the RATA Benefit at PPA

• On 23 October 1989, PPA issued Memorandum Circular No. 36-89, extending the RATA benefit at a reduced rate of 20% to lower-ranking officials such as Section Chiefs, Terminal Supervisors, and senior personnel.
• Subsequently, on 14 November 1990, PPA issued Memorandum Circular No. 46-90, increasing the RATA for these officials from 20% to 40% effective 1 January 1990, following the standardized salary adjustments mandated by R.A. No. 6758.
• The continued validity of the maximum 40% RATA was later supported by opinions from the Office of the Government Corporate Counsel (OGCC) and other legal interpretations within the government.

COA’s Post-Audit Disallowances and the Resulting Conflict

• The Commission on Audit (COA) disallowed:
• The post-audit payment of RATA differentials made by the PPA officials due to their salary adjustments.
• The payment of RATA to officials holding salary grades of 17 and above who were appointed after the effectivity of R.A. No. 6758.
• COA’s disallowance was based on Memorandum No. 90-679 (dated 30 October 1990), clarifying that LOI No. 97 was replaced by Section 16 of R.A. No. 6758.

The Emergence of Two Categories of PPA Officials

• First Category:
• Officials who were incumbents as of 1 July 1989 and were already receiving the 40% RATA under LOI No. 97.
• These individuals continued to enjoy the maximum benefit.
• Second Category:
• Officials who either were not incumbents as of 1 July 1989 or were appointed/promoted after this date.
• These officials were, therefore, receiving a lower RATA benefit under the General Appropriations Act.

The Litigation Process

• In July 2000, petitioners (second category officials) filed a Petition for Mandamus and Prohibition before the RTC of Manila, Branch 55, asserting that they were entitled to the 40% RATA based on:
• New developments allegedly arising from the Supreme Court decision in De Jesus v. Commission on Audit, et al.
• Issuances from the COA and the Department of Budget and Management (DBM) which purportedly extended the cut-off date for the 40% RATA grant.
• PPA moved to dismiss the petition on the ground of res judicata, arguing that the matter had already been settled in the earlier case of PPA v. COA, et al.
• The RTC granted the motion to dismiss on 8 November 2000 on the basis of res judicata.
• Petitioners elevated the case to the Supreme Court via Rule 45, which then referred the matter to the Court of Appeals (CA), docketed as CA-G.R. SP No. 64702.
• On 31 July 2002, the CA determined that res judicata was not applicable, reasoning that new facts (the DBM and COA issuances) provided a distinct basis for the claims, thereby necessitating further proceedings.
• After remand and trial proceedings, the RTC rendered a decision in favor of petitioners on 10 August 2005, ordering PPA to pay the 40% RATA starting either from their dates of appointment or from 23 October 2001 (the date when the Irene V. Cruz case ruling came into effect).
• PPA appealed the RTC decision, and on 29 August 2007 the CA reversed the trial court’s ruling, dismissing the petition. PPA later denied the petitioners’ motion for reconsideration on 29 February 2008.
• The present petition is a Petition for Review on Certiorari challenging the CA’s reversal and the subsequent denial of reconsideration.

Issue:

Whether the principle of res judicata is applicable in the instant case in light of the CA’s earlier ruling in CA-G.R. SP No. 64702.

• Petitioners argue that the non-appealed decision in CA-G.R. SP No. 64702 should bar the current petition by res judicata.
• PPA contends that the previous ruling did not attain finality and should not preclude the current claims.

Whether PPA, in denying the 40% RATA claim to petitioners, violated their constitutional right to equal protection of the law.

• Petitioners contend that withholding the benefit creates a disparity contrary to the equal protection principle, especially given the transitional arrangements of R.A. No. 6758.

• Whether petitioners are justified in receiving the 40% RATA and should not be required to refund the RATA they had received in good faith under the previous guidelines.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)