G.R. No. L-34676 - Ligot vs. Mathay

Benjamin T. Ligot served as a member of the House of Representatives for three consecutive four‐year terms.
His service spanned a twelve-year period from December 30, 1957, to December 30, 1969.

The Act increased the salaries of constitutional and certain national government officials.
The salary for members of Congress (both senators and congressmen) was increased from P7,200 per annum to P32,000 per annum.

Section 7 of the Act provided that the increased salary would take effect on July 1, 1964.
However, the Act expressly indicated that the salary increase “shall take effect in accordance with the provisions of the Constitution.”

The 1935 Constitution (Article VI, Section 14) mandates that no increase in the salary or other emoluments shall take effect until after the expiration of the full term of all members of Congress who approved the increase.
In Philconsa vs. Mathay, the Court clarified that the increased compensation of P32,000 per annum would only become operative for incoming members whose terms commenced after the full expiration of the terms of those who approved the increase.

After losing his bid for a consecutive fourth term in the 1969 elections, Petitioner’s term expired on December 30, 1969.
He filed a claim for retirement benefits under Commonwealth Act 186, as amended by Republic Act 4968, which allowed retirement gratuity for officials or employees with at least twenty years of government service.

The House of Representatives issued a treasury warrant on May 8, 1970, reflecting the higher salary computation.
Concerns arose when Auditor Velasco, upon learning of a similar claim by ex-Congressman Melanio T. Singson, requested a return of the warrant for recomputation.

The Auditor-General issued an adverse decision regarding Singson’s claim, applying the constitutional mandate.
Petitioner’s subsequent request for reconsideration was denied by the Auditor General on January 20, 1972.
Petitioner then elevated his dispute to the Court through a petition for review, arguing that his retirement gratuity should be computed on the statutory increased salary (P32,000 per annum).

Whether retirement gratuity for outgoing members of Congress should be computed based on the salary actually received during their term (P7,200 per annum) or on the increased statutory salary (P32,000 per annum) as provided by Republic Act No. 4134.
Whether computing the retirement benefit on the increased salary effectively circumvents the constitutional prohibition against increasing legislators’ compensation during their term of office.
Whether allowing the increased computation would indirectly award prohibited emoluments that were not legally received during the petitioner’s incumbency.