G.R. No. 254757 - Villanueva vs. Sugar Regulatory Administration

The Sugar Regulatory Administration (SRA) was created by Executive Order No. 18 in 1986, tasked with promoting the growth and development of the sugar industry.
In 2007, EO No. 631 declared the SRA as a government-owned and controlled corporation (GOCC).
Republic Act No. 10149 (GOCC Governance Act of 2011) created the Governance Commission for GOCCs (GCG) as the central policy-making body to oversee GOCCs' operations and governance, and authorized the GCG to evaluate relevant GOCCs and develop competitive compensation systems.
EO No. 203, series of 2016, issued by then-President Benigno S. Aquino III, provided for adoption of a Compensation and Position Classification System (CPCS) and authorized granting of Early Retirement Incentive Programs (ERIPs).
RA 10659 (Sugarcane Industry Development Act of 2015) aimed to promote competitiveness and improve incomes in the sugarcane industry.

The SRA formulated the RATPLAN in 2015 to strengthen and reorganize its structure, proposing 454 plantilla positions.
The GCG approved the RATPLAN on April 12, 2016 under Memorandum Order (MO) No. 2016-05, setting conditions including adopting an early retirement and separation package using EO No. 203 incentives.
The SRA invited employees to avail of the ERIP, and petitioners among the affected personnel opted for early retirement effective August 1, 2016.
The SRA approved a supplemental budget for the ERIP on June 13, 2016 and submitted it to the Department of Budget and Management (DBM) for approval.
The DBM did not approve the supplemental budget due to the absence of implementing guidelines for EO No. 203, as reiterated by the GCG in August 2016.

The GCG advised the SRA to withhold ERIP payments pending issuance of implementing guidelines.
Petitioners who retired effective August 1, 2016 did not receive ERIP benefits and were taken off payroll.
69 petitioners filed a complaint before the Civil Service Commission (CSC) for illegal dismissal and payment of back salaries and benefits, claiming non-payment of retirement benefits amounted to illegal dismissal.
The CSC dismissed the complaint for lack of merit but directed the SRA to facilitate the payment of ERIP benefits with dispatch.
Petitioners submitted letters to the SRA and petitioned the Ombudsman for non-compliance with the CSC decision.
The GCG issued Memorandum Circular No. 2017-03 implementing EO No. 36, which suspended EO No. 203 including ERIP provisions.
Petitioners appealed to the Office of the President (OP) for release of ERIP benefits; their requests were unanswered.

Petitioners filed a petition for mandamus before the Supreme Court seeking to compel respondents (SRA, GCG, and DBM) to release their ERIP benefits.
The Office of the Solicitor General (OSG) filed comments raising procedural and substantive objections.
The petition is supported by petitioners despite incomplete certification signatures and alleged forum shopping concerns.
The Court scheduled the case for resolution amidst back-and-forth filings and further motions.

Whether the petition for mandamus filed directly before the Supreme Court violated the hierarchy of courts principle requiring the petition to have been filed before a lower court.

Whether the petitioner's failure to have all petitioners sign the certification against forum shopping and alleged false certification justifies outright dismissal.

Whether petitioners have a clear and unmistakable legal right to receive their ERIP retirement benefits and whether respondents have a ministerial duty to release these benefits.

Whether respondents unlawfully neglected the performance of their duty mandated by law, justifying the issuance of a writ of mandamus to compel payment of the ERIP benefits.