Case Digest (G.R. No. 218097) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Government Service Insurance System v. Apolinario K. Daymiel, the petitioner, GSIS, questioned the Regional Trial Court’s authority to entertain a declaratory relief action filed by respondent Apolinario K. Daymiel (now substituted by his heirs) in Dipolog City. Daymiel began his public service on August 18, 1969 as a casual laborer in the Provincial Engineering Office of Zamboanga del Norte and later became Accounting Clerk III until his retirement on July 1, 2003. Upon application for retirement benefits, GSIS’s initial computation credited him with 33.65678 years of service, yielding a lump-sum payment of ₱542,325.00 and a monthly pension of ₱9,038.75. Shortly before his retirement, GSIS issued Policy and Procedural Guidelines No. 171-03 (March 24, 2003) and Resolution No. 90 (April 2, 2003), which redefined the starting point for computing creditable service as the date of payment of monthly contributions. Under this reinterpretation, GSIS recomputed Daymiel’s service at Case Digest (G.R. No. 218097) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and Retirement Application
- Apolinario K. Daymiel served as a casual laborer in the Provincial Engineering Office of Zamboanga del Norte beginning August 18, 1969, and later as Accounting Clerk III until his retirement on July 1, 2003.
- He applied for retirement benefits with the GSIS, for which an initial computation credited him with 33.65678 years of service, a lump sum of ₱542,325.00, and a monthly pension of ₱9,038.75.
- Re-computation and Issuances
- GSIS re-computed his service at 23.85082 years based on Policy and Procedural Guidelines No. 171-03 (PPG No. 171-03, March 24, 2003) and GSIS Board Resolution No. 90 (April 2, 2003), reducing his benefits to a ₱384,295.80 lump sum and ₱5,886.77 monthly pension.
- PPG No. 171-03 defined “services” for computation purposes as those with fixed monthly compensation and timely remitted contributions, in contrast to RA 8291’s definition from date of original appointment.
- Procedural History
- Before the RTC of Dipolog City, Daymiel filed for declaratory relief, mandamus, and damages. The GSIS moved to dismiss for lack of cause and jurisdiction. The RTC initially granted dismissal, then reversed, invalidating PPG No. 171-03/Resolution No. 90 for non-publication, but ultimately dismissed for lack of jurisdiction under Section 30, RA 8291.
- On appeal, the CA reversed in February 2014, declared the issuances null and void for lack of publication, and directed recomputation from original appointment. A GSIS motion for reconsideration was denied in April 2015. GSIS filed a Rule 45 petition with the Supreme Court.
Issues:
- Whether the RTC has jurisdiction to entertain Daymiel’s petition for declaratory relief attacking the validity of GSIS administrative issuances.
- Whether PPG No. 171-03 and GSIS Resolution No. 90 are valid despite their non-publication.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)