Title
Bengzon vs. Drilon
Case
G.R. No. 103524
Decision Date
Apr 15, 1992
Retired Justices challenged President Aquino's veto of pension adjustments in the 1992 budget, arguing PD 644's repeal of RA 1797 was invalid. The Supreme Court ruled the veto unconstitutional, upholding retirees' vested rights and fiscal autonomy of the Judiciary.
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Case Digest (G.R. No. 103524)

Facts:

  1. Background of Retirement Laws:

    • Republic Act No. 910 (enacted June 20, 1953) provided retirement pensions for Justices of the Supreme Court and Court of Appeals who served at least 20 years and reached the age of 70 or resigned due to incapacity. The pension was equivalent to the salary received at retirement.
    • Republic Act No. 1797 (enacted June 21, 1957) amended RA 910, allowing automatic adjustment of pensions if the salaries of active Justices were increased or decreased.
    • Similar retirement benefits were extended to members of the Constitutional Commissions under RA 1568, as amended by RA 3595.
  2. Presidential Decrees and Repeals:

    • Presidential Decree (PD) 578 (November 12, 1974) extended similar retirement benefits to members of the Armed Forces, including automatic pension adjustments.
    • PD 644 (January 25, 1975) repealed Section 3-A of RA 1797 and RA 3595, removing the automatic adjustment of pensions for retired Justices and members of Constitutional Commissions.
    • PD 1638 and PD 1909 later restored automatic pension adjustments for retired military personnel but not for retired Justices.
  3. Congressional Action and Presidential Veto:

    • In 1990, Congress passed a bill to reenact the repealed provisions of RA 1797 and RA 3595, aiming to restore automatic pension adjustments for retired Justices.
    • President Aquino vetoed the bill on July 11, 1990, citing concerns about violating the standardization of compensation under RA 6758 (Compensation and Position Classification Act of 1989).
  4. Petition for Pension Adjustment:

    • Retired Justices Manuel P. Barcelona, Juan P. Enriquez, Juan O. Reyes, Jr., and Guardson R. Lood filed a petition on April 22, 1991, seeking pension adjustments under RA 1797. They argued that PD 644, which repealed RA 1797, was not validly published and thus had no legal effect.
    • The Supreme Court granted their request in a resolution dated November 28, 1991, authorizing the adjustment of their pensions effective January 1, 1991.
  5. General Appropriations Act for FY 1992:

    • Congress included provisions in the General Appropriations Act for FY 1992 to fund the adjusted pensions of retired Justices, as per the Court’s resolution.
    • President Aquino vetoed these provisions, leading to the instant petition challenging the constitutionality of the veto.

Issue:

  1. Whether the President’s veto of the provisions in the General Appropriations Act for FY 1992, which appropriated funds for the adjusted pensions of retired Justices, is constitutional.
  2. Whether retired Justices have a vested right to the automatic adjustment of their pensions under RA 1797.
  3. Whether the veto impairs the fiscal autonomy of the Judiciary.

Ruling:

The Supreme Court granted the petition and declared the President’s veto illegal and unconstitutional. The vetoed provisions of the 1992 Appropriations Act were upheld as valid and subsisting. The Court ordered the respondents to release the funds for the adjusted pensions and implement the resolution in Administrative Matter No. 91-8-225-CA.

Ratio:

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