Title
Arenas vs. City of San Carlos, Pangasi
Case
G.R. No. L-34024
Decision Date
Apr 5, 1978
City judge Arenas sought salary differential under RA 5967, but SC ruled proviso limiting judge's salary to P100 less than mayor's prevails, denying claim.
A

Case Summary (G.R. No. L-34024)

Procedural History

Petitioner Arenas filed a petition for mandamus in the Court of First Instance of Pangasinan (San Carlos City, Branch X) in January 1971 seeking enforcement against the city and its officials to pay the salary differential allegedly due under Republic Act No. 5967. The trial court dismissed the mandamus petition by decision dated May 31, 1971. The present matter is a petition for certiorari to review that dismissal.

Factual Background

When RA No. 5967 took effect (June 21, 1969), San Carlos City was a third-class city. Petitioner was receiving an annual salary of P12,000.00 (P1,000.00 per month), composed of P350.00 from the national government and P650.00 from the city, which the petitioner alleged was P500.00 per month below the statutory basic salary for a city judge of a third-class city under RA No. 5967 (P18,000.00 per annum). Petitioner claimed entitlement to a salary differential amounting to P9,500.00 from June 21, 1969 to the filing date (January 21, 1971) and alleged repeated requests to respondents to enact the necessary budget, all of which were refused. Petitioner asserted lack of any plain, adequate and speedy remedy other than mandamus and sought attorney’s fees of P2,000.00.

Respondents’ Position

The respondents denied liability and asserted that RA No. 5967 contains a proviso that the salary of a city judge shall be at least P100.00 per month less than that of the city mayor. They stated that the city judge in San Carlos was receiving P12,000.00 per year and the city mayor P13,200.00 per year (exactly P100.00 per month more). Respondents further alleged that the payment of any salary difference under RA No. 5967 is subject to implementation by the respective city government and that payment was discretionary and constrained by the city’s financial difficulties, including a large overdraft. Respondents contended petitioner should bear his own attorney’s fees.

Statutory Provision in Dispute

Section 7 of RA No. 5967 (as quoted in the record) sets minimum basic salaries for city judges and contains the proviso: “Provided, however, That the salary of a city judge shall be at least one hundred pesos per month less than that of the city mayor.” The section also provides (for second and third class cities) a basic salary stated as P18,000.00 per annum for city judges and includes comparative phrases referencing district judges’ salaries.

Petitioner’s Argument on Statutory Construction

Petitioner argued that the principal salary schedule in Section 7 (fixing P18,000.00 for city judges of second and third class cities) manifests the legislature’s primary intent to increase city judges’ salaries and that the proviso should not be interpreted to nullify that primary provision. He urged that the proviso be subordinated to the principal provision so as to effectuate the intended salary increase.

Legislative History and Congressional Intent

The Court reviewed Senate deliberations on the bill that became RA No. 5967. The quoted discussions show senators expressed concern that, without amendment, some city judges might receive higher salaries than city mayors. The Senate amendment and the discussion surrounding it demonstrate an intent that city judges’ salaries not exceed those of mayors; the proviso was explained as a limiting measure to prevent judges from receiving salaries higher than the chief city executive.

Court’s Legal Analysis on Construction and Priority of Proviso

The Court applied conventional rules of statutory construction: a proviso is intended to qualify or limit the general language of a statute. Where there is an irreconcilable repugnancy between the principal provision and the proviso, the proviso—being the later expression of legislative intent within the same statutory section—controls and limits the broader language. Given the legislative history and the clear limiting language of the proviso, the Court concluded that the proviso qualified the earlier salary schedule and that Congress intended that the salary of a city judge should not exceed (and must be at least P100.00 less than) the salary of the city mayor.

Application of Law to the Facts

Because the city mayor of San Carlos was receiving an annual salary of P13,200.00 (P1,100.00 per month) and the proviso required the city judge’s salary to be at least P100.00 per month less, the Court held respondents could not be compelled to provide the petitioner with an annual salary of P18,000.00. The

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