Case Digest (G.R. No. 88979) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lydia O. Chua v. Civil Service Commission, National Irrigation Administration, and Department of Budget and Management (G.R. No. 88979, February 7, 1992), petitioner Lydia Chua, a personnel assistant assigned to successive World Bank–assisted irrigation projects of the National Irrigation Administration (NIA) since December 2, 1974, applied on January 30, 1989 for early retirement benefits under Republic Act No. 6683, which took effect on December 2, 1988. Although she had rendered nearly fifteen years of continuous service and met the two-year service requirement, NIA denied her claim and offered only separation pay equivalent to one-half month’s salary per year of service. The Civil Service Commission (CSC) affirmed the denial on the ground that petitioner’s co-terminous employment status as of December 2, 1988, was contractual in nature and excluded from the coverage of RA 6683. Petitioner then filed a special civil action for certiorari before the Supreme Court seeking th Case Digest (G.R. No. 88979) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment of Republic Act No. 6683
- Approved on 2 December 1988 to streamline and trim the bureaucracy by providing benefits for early retirement, voluntary separation, and involuntary separation due to reorganization.
- Coverage (Sec. 2): all appointive officials and employees of the national government (including GOCCs with original charters) and personnel of local government units—regular, temporary, casual, and emergency employees with at least two (2) consecutive years of service; excludes uniformed AFP/PC-INP personnel.
- Petitioner’s employment and benefit application
- Lydia O. Chua served from December 1974 to December 1988 in four successive NIA projects, initially as emergency/temporary laborer and research aide, later appointed permanent Personnel Assistant A with co-terminous status tied to project duration.
- She applied on 30 January 1989 for RA 6683 benefits; NIA denied her application and offered separation pay at ½-month basic pay per year of service.
- Administrative recourse
- Chua appealed to the Civil Service Commission (CSC); CSC denied reconsideration, citing Joint DBM-CSC Circular No. 89-1 requirement that applicant’s status as of enactment (2 December 1988) be casual, emergency, temporary, or regular—contractual/co-terminous employees excluded.
- Petitioner filed a special civil action for certiorari with the Supreme Court, contending she met RA 6683 requirements and was not among exclusions under implementing guidelines.
Issues:
- Are co-terminous/project employees entitled to the benefits of RA 6683 and its implementing guidelines?
- Did NIA and the CSC commit grave abuse of discretion in denying petitioner’s application for early retirement benefits under RA 6683?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)