A.M. No. 747-RET - IN RE: Martin

Ruperto G. Martin, former Associate Justice of the Supreme Court, suffered a cerebral stroke on January 1, 1978.
At the time of the stroke, he was 64 years, 9 months, and 13 days old—short of the compulsory retirement age of 65 as prescribed by Article X, Section 7 of the 1973 Constitution.

Martin applied for disability retirement under Section 3 of Republic Act (RA) 910, as amended.
Medical certificates by Dr. Yolando Q.M. Sulit and Dr. Carmen C. Valero confirmed that the stroke resulted in lasting impairments, including left-side paralysis, facial paralysis, slurred speech, and general body weakness.
The underlying condition was diagnosed as Cerebral Infarction secondary to Cerebral Thrombosis, considered a permanent disability.

On January 10, 1978, the Court En Banc approved his application by resolution.
The resolution certified his permanent disability contracted during his incumbency and noted that he was incapacitated to continue serving as Associate Justice.
The benefits granted included a ten-year lump sum retirement gratuity (amounting to P624,000) with no further monthly pension annuity, in accordance with Section 3 of RA 910 as amended.

Martin’s government service commenced in 1938, totaling 22 years, 5 months, and 12 days.
Out of his total service, 12 years and 11 days were continuously rendered in the judiciary.
Under Section 3 of RA 910, disability retirement benefits were prescribed to be a ten-year salary equivalent lump sum intended to help cover medical and hospital expenses.

Eleven years after his initial retirement, on September 9, 1989, Martin applied for a lifetime pension under Section 1 of RA 910, asserting that he had already “earned a vested right” to such benefits by virtue of his age (over 60) and elongated government service (over 20 years, with the last five in the judiciary).
Section 1 of RA 910 provides that eligible retirees may receive a monthly pension for the rest of their natural life, following a five-year lump sum and subsequent annuity after retirement.
The Court initially denied his request in a resolution dated November 21, 1989, based on the explicit provision in Section 3 that limits benefits for retirements due to permanent disability.

Upon filing a motion for reconsideration, the Appellate Court reviewed and re-examined its previous position.
The Court found merit in a liberal interpretation of Section 3 of RA 910, emphasizing that retirement laws should be construed in favor of the retiree.
It noted that the primary purpose of the ten-year lump sum was to assist in medical and hospital expenses, not to penalize the retiree by depriving him of his lifetime pension benefits if he survived beyond ten years.
The Court ruled that if a retiree under Section 3 later survives the ten-year period, the disability retirement may be converted into an application for voluntary retirement under Section 1, with the ten-year lump sum counted as a part-payment of the five-year lump sum.

Whether the receipt of the ten-year lump sum under Section 3 by virtue of disability retirement precludes the retiree from later claiming a lifetime pension under Section 1 when he meets the eligibility requirements.
Whether a retiree, who by reason of permanent disability has opted for Section 3 benefits, has forfeited his accrued right to the lifetime annuity option provided under Section 1.

The proper interpretation of retirement provisions in light of the humanitarian intent to support government employees upon retirement.
Whether the disability retirement benefit, aimed at addressing medical and hospital expenses, should be applied in a manner that does not leave the retiree without long-term financial security.

Whether the ten-year lump sum payment can be deemed as a part payment toward the five-year lump sum required under Section 1.
If such conversion entitles the petitioning retiree to a monthly pension for the remainder of his natural life.