Title
Republic vs. Pryce Corp., Inc.
Case
G.R. No. 243133
Decision Date
Mar 8, 2023
The Supreme Court ruled that interment services are included in the 20% discount on funeral and burial services for senior citizens under RA 7432, as amended, overturning the RTC's decision.

Case Digest (G.R. No. 243133)

Facts:

Republic of the Philippines, through the Office of the Solicitor General, Office of the Senior Citizens Affairs (OSCA), Department of Social Welfare and Development (DSWD) v. Pryce Corporation, Inc., G.R. No. 243133, March 08, 2023, the Supreme Court En Banc, Zalameda, J., writing for the Court.

Pryce Corporation, Inc. (respondent) is a domestic company selling memorial lots and providing interment services. On 29 October 2015, respondent filed a special civil action for declaratory relief in the Regional Trial Court (RTC), Branch 17, Cagayan de Oro City (Civil Case No. CV-ORD-2015-215), asking the RTC to determine whether the statutory 20% senior citizen discount on “funeral and burial services” under Republic Act No. 7432, as amended by RA 9257 and RA 9994, includes interment services. Respondent contended interment services are not covered and therefore it should not be compelled to grant the discount on those services.

Petitioners—the Republic through the Office of the Solicitor General representing OSCA and DSWD—moved to dismiss, arguing that the requisites for declaratory relief were not all present and that the statutory language was plain and unambiguous, so no judicial interpretation was needed. They urged that “funeral and burial services” should be read in its ordinary meaning to include the ceremony and the act of burying the remains.

The RTC, in a Resolution dated 18 January 2018, found the requisites for declaratory relief present but construed the Implementing Rules and Regulations (IRR) of RA 9994 to exclude interment services from the list of services entitled to the 20% discount, since the IRR enumerated items (casket or urn, embalming, hospital morgue, transport of the body) and did not expressly list interment. The RTC denied petitioners’ motion for reconsideration in a 22 October 2018 R...(Pro-only)

Issues:

  • Before addressing the substantive question, are the requisites for an action for declaratory relief present and is the case justiciable and ripe for judicial determination?
  • Whether “interment services” are included within the phrase “funeral and burial services” under RA 7432 as amended by RA 9257 and RA 9994, and therefore subject to the ...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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