G.R. No. L-35645 - People vs. V.M. Ruiz

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G.R. No. L-35645: People vs. V.M. Ruiz

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Title Source: Supreme Court: Cawad vs. Abad

Case: G.R. No. 207145

Decision Date: Jul 28, 2015

Public health workers challenged joint circulars limiting RA 7305 benefits; SC upheld most provisions but invalidated reduced hazard pay and unenforceable step increment rules.

Case Digest (G.R. No. L-35645)
Expanded Legal Reasoning Model

Facts:

Magna Carta of Public Health Workers (RA No. 7305, March 26, 1992)

Sections 20–23 granted PHWs hazard allowance, subsistence allowance, longevity pay.
Section 35 required DOH to issue IRR after consultation with agencies and health workers’ organizations; IRR effective 30 days after publication.

DOH Implementing Rules and Regulations

July 1992 IRR; November 1999 Revised IRR consolidated clarifications.
Key provisions of Revised IRR:

Hazard pay eligibility only if nature of work exposes PHW to high/low risk ≥ 50% of hours (Sec 7.1.1).
Subsistence allowance not less than ₱50/day or ₱1,500/month; part-time at ½ rate (Sec 7.2.3).
Longevity pay 5% of basic pay every 5 years for continuous, meritorious service (Sec 6.3).

Joint Resolution No. 4 (2008/approved June 17, 2009)

Authorized DBM to rationalize compensation and classify plantilla.
Removed DOH consultative-council role in issuing Magna Carta implementing rules.

Assailed Issuances

DBM-CSC Joint Circular No. 1, s. 2012 (September 3, 2012):

“An official or employee authorized to be granted Longevity Pay under existing law is not eligible for Step Increment due to length of service” (Item 6.5).

DBM-DOH Joint Circular No. 1, s. 2012 (November 29, 2012):

Hazard pay granted only during actual exposure and based on high/low risk classification.
Subsistence allowance fixed at ₱50/day full-time, ₱25/day part-time.
Longevity pay 5% of current basic pay every 5 years, only for plantilla regular positions with satisfactory ratings.

Petition for Certiorari and Prohibition (May 30, 2013)

Petitioners: PPHAI officers and members.
Respondents: DBM Secretary, DOH Secretary, CSC Chairman.
Allegations: Circulars diminish Magna Carta benefits; impose additional qualifications; fix lower rates; premature effectivity; undue exercise of legislative power; lack of consultation; budget omission.

Issues:

Whether the DBM-DOH Joint Circular No. 1, s. 2012 was issued with grave abuse of discretion or violated substantive due process by:

Making hazard pay dependent on actual days of exposure.
Fixing subsistence allowance at ₱50/₱25 without prevailing-circumstances consultation.
Limiting longevity pay to plantilla regular positions.
Becoming effective January 1, 2013 without 30-day publication period.

Whether DBM-CSC Joint Circular No. 1, s. 2012 was issued with grave abuse of discretion by withholding Step Increment due to length of service from those entitled to longevity pay.

Whether the DBM-DOH Joint Circular is void as an undue exercise of legislative power by administrative bodies in formulating Magna Carta implementing rules.

Whether the DOH Secretary was remiss in not including Magna Carta benefits in the annual departmental budget.

Whether the DBM-DOH Joint Circular is void for failure to consult professional and health-workers’ organizations and unions.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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END