A.M. No. 19-02-03-CA. - Re: Expenses of Retirement of Court of Appeals Justices

On June 25, 2019, the Court issued a Resolution in Administrative Matter No. 19-02-03-CA approving an increase in the allocated retirement program budget for the Court of Appeals.
The approved amounts were set at:

On September 3, 2019, the Court of Tax Appeals (CTA) En Banc convened and passed Resolution No. 4-2019.
The CTA’s resolution invoked the policy on retirement program budgets established for the Court of Appeals based on the equality in level provided by Section 1 of Republic Act No. 1125, as amended.
Through a letter dated September 4, 2019, CTA Presiding Justice Roman G. Del Rosario formally transmitted the resolution and expressed the hope that the policy be likewise applied to the CTA.
A subsequent letter dated January 8, 2020, reiterated the request, highlighting the urgency due to the imminent retirement of Associate Justices.

Atty. Corazon G. Ferrer-Flores, Deputy Clerk of Court and Chief of the Fiscal Management and Budget Office (FMBO), submitted her Comment on December 16, 2019.
Her comment recommended applying the approved retirement program budget of the Court of Appeals to both the CTA and the Sandiganbayan, citing uniformity, as both courts are at the same level.
She provided comparative analyses indicating that the retirement program budgets of the CTA and the Sandiganbayan were presently much lower than that of the Court of Appeals, especially on a per-employee basis.

The CTA was originally created on June 16, 1954 by Republic Act No. 1125 and later elevated to a collegiate court with the same level as the Court of Appeals via R.A. No. 9282.
The Sandiganbayan, established as a special court by Presidential Decree No. 1486 and later confirmed to be of the same level as the Court of Appeals by P.D. No. 1606, has maintained a lower retirement program budget compared to the Court of Appeals.
Statutory provisions mandate that the judiciary justices of these courts have the same rank, salary, privileges, and retirement benefits; however, retirement program budgets are administrative expenses and not statutory benefits.

The increase in the retirement program budget for the Court of Appeals was primarily justified by the significant number of employees (1,660) that necessarily increased the overall cost of the retirement program.
The items covered under the increased budget include luncheon/dinner receptions, judicial tokens, miscellaneous expenses related to special sessions, souvenirs, and food stubs for employees.
A comparative table was provided showing that, although on a per-employee basis the CTA and Sandiganbayan had higher budgets, the total expense for the Court of Appeals justified a higher overall allocation.

The retirement program budgets are not mandated by any explicit statute but are regarded as administrative expenses allotted by the Court.
These budgets are determined at the Court’s discretion, considering factors such as actual costs of retirement activities, number of employees, time elapsed since the last increase, and the availability of funds.
Prior to the CA’s increase, the CTA and the Sandiganbayan enjoyed higher retirement program budgets despite having fewer employees, but this did not automatically entitle them to similar increases.

Whether the policy on increasing the retirement program budget for the Court of Appeals should automatically extend to courts of equal rank such as the CTA and the Sandiganbayan.

Does the statutory equality in rank, salary, and privileges obligate the extension of the same administrative budget increase?
Is the significant difference in the number of employees a valid justification for differential treatment in the retirement program budgets?

Whether the CTA provided sufficient evidence and justification for the need to increase its retirement program budget.

Was there adequate certification from the appropriate fiscal officers regarding the availability of funds?
Did the CTA convincingly show that rising costs due to inflation necessitate a corresponding increase in budget?

How should the discretionary nature of retirement program budgets be interpreted in light of the absence of a statutory mandate.