G.R. No. 212719 - Inmates of the New Bilibid Prison vs. De Lima

The issue arose from applications for survivorship pension benefits filed by the legitimate spouses of justices and judges who died prior to the effectivity of Republic Act (R.A.) No. 9946.
The applications involve questions on whether these surviving spouses are entitled to the benefits provided under the amended law.
The Court’s resolution was issued en banc, addressing conflicting positions raised by the Special Committee on Retirement and Civil Service Benefits.

R.A. No. 910, enacted in 1954, provided for retirement and death benefits for justices and judges under specific age and service requirements.
Subsequent legislation, including R.A. No. 2614 and more importantly R.A. No. 9946 (effective February 11, 2010), expanded the coverage and modified the benefits and qualification requirements.
The new law introduced key changes:

Inclusion of survivorship pension benefits for the surviving legitimate spouse.
Provision for an automatic increase in pension benefits (Section 3-A) whenever the salary for the position is raised.
A retroactivity clause (Section 3-B) extending benefits to members of the Judiciary who retired or died prior to the law’s effectivity.

Under the original R.A. No. 910, a justice or judge was entitled to retirement benefits (compulsory or optional) and lump sum death benefits based on years of service.
R.A. No. 9946 significantly upgraded these benefits and introduced features such as:

Full monthly pension or pro rata pension for surviving spouses, depending on service length (at least 15 years or less than 15 years).
A table summarizing the revised benefits, including lump sum gratuities (5-year or 10-year) and automatic adjustments pursuant to salary increases.

The guidelines provided in Revised Administrative Circular (RAC) No. 81-2010 were also amended to reflect these changes.

The Court considered memoranda from the Special Committee on Retirement and Civil Service Benefits, with differing recommendations:

Memorandum A (dated 23 June 2017) recommended approval of the applications.
Memorandum B (dated 6 July 2017) recommended their denial, following the technical arguments from the SC-RCSB Technical Working Group (TWG).

The Gruba case – where survivorship benefits were initially granted and later modified based on the deceased judge’s eligibility for optional retirement.
The Vilches case – involving a Deputy Court Administrator who did not satisfy the age requirement for optional retirement, affecting the grant of survivorship pension benefits.
The Alvor case – where pro rata survivorship benefits were granted even though the judge was not eligible for retirement at the time of death.

The Office of the Court Administrator (OCA) recommended revisiting previous decisions in light of the new law and its retroactive application.

The interpretation of key terms such as “retired” and “eligible to retire optionally” in the context of R.A. No. 9946.
Whether the benefits under R.A. No. 9946, including the survivorship pension and automatic adjustment, should be applied retroactively to those justices and judges who died before the law’s effectivity.
The inclusion of justices and judges who, although not having formally retired, died while still in active service, and those who served in capacities such as Court Administrators or Deputy Court Administrators.

Who qualify as “surviving spouses” under Section 3, paragraph 2, of R.A. No. 9946, particularly when the deceased justice or judge had not formally retired but was eligible for retirement at the time of death.
Whether the surviving spouse of a justice or judge who died or was killed while in active service is entitled to the survivorship benefit.

Does Section 3-B, which provides for the retroactive application of R.A. No. 9946, extend the benefits to justices or judges who died prior to the effectivity of the law?
Whether the retroactive application should include cases where the deceased did not meet the retirement age but was eligible for optional retirement.

What are the specific benefits (full monthly pension versus pro rata pension) to which the surviving spouse is entitled based on the length of government service rendered by the deceased justice or judge?
How should the adjustments mandated under Section 3-A (automatic increase in pension benefits) be applied to these survivorship benefits?

Whether appointments to positions such as Court Administrator or Deputy Court Administrator, while preserving judicial rank, affect the entitlement of survivorship benefits.
Clarification on the definition of “member of the Judiciary” in the context of the benefits provided.