Case Digest (G.R. No. 109406) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioners, numbering in the hundreds, are permanent, full-time, temporary, casual and contractual employees of various national and local government departments, agencies and government-owned or ‑controlled corporations (GOCCs), who received Productivity Incentive Benefits for Calendar Year 1992 in varying amounts under Executive Order No. 292 (“EO 292”) and the Omnibus Rules Implementing Book V of EO 292. On January 19, 1993, President Fidel V. Ramos issued Administrative Order No. 29 (“AO 29”) authorizing the grant of Productivity Incentive Benefits for 1992 up to a maximum of ₱1,000 and reiterating the prohibition in Administrative Order No. 268 (“AO 268”) against granting incentives beyond 1991 without prior Presidential approval. AO 29 further directed agencies to recover any excess payments. Agency heads accordingly deducted alleged overpayments from salaries and allowances. Petitioners filed consolidated petitions for certiorari and prohibition before the Supreme Court Case Digest (G.R. No. 109406) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidated Petitions (G.R. Nos. 109406, 110642, 111494, 112056)
- Petitioners, officials and employees of various national and local government agencies and GOCCs, received Productivity Incentive Benefits (PIB) for calendar year (CY) 1992 pursuant to Executive Order (EO) 292 (the 1987 Administrative Code) and the Omnibus Rules implementing Book V of EO 292.
- On January 19, 1993, President Ramos issued Administrative Order (AO) 29, limiting CY 1992 PIB to a maximum of ₱1,000 each (Section 1) and directing refund of any excess (Section 4). AO 29 also reiterated the prohibition (Section 7) of AO 268 (February 21, 1992) against granting similar benefits for CY 1992 and subsequent years without presidential approval. Agency heads, including COA auditors, thereafter deducted alleged overpayments from petitioners’ salaries or allowances. Petitioners sought injunctive relief against further deductions, arguing AOs 29 and 268 violated EO 292, usurped Civil Service Commission (CSC) authority, and impaired contractual obligations.
- Petition in G.R. No. 119597
- The Association of Dedicated Employees of the Philippine Tourism Authority (ADEPT) represented PTA employees who had been granted CY 1992 productivity bonuses under Republic Act (RA) 6971 (Productivity Incentives Act of 1990).
- COA disallowed these bonuses, citing AO 29’s prohibition. The COA denied ADEPT’s appeal on grounds RA 6971 applies only to private enterprises and GOCCs incorporated under the Corporation Code, not to GOCCs with special charters subject to civil service. ADEPT petitioned the Court to overturn the COA decision and challenge the validity of AOs 29 and 268.
Issues:
- Coverage of RA 6971
- Validity of AOs 268 and 29
- Contractual Impairment
- Personal Liability
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)