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.

Case Summary (G.R. No. 60210)

Background of the Petition

The petitioner filed a petition for mandamus on January 21, 1971, against the City of San Carlos and its officials, alleging non-compliance with the salary provisions outlined in Republic Act No. 5967. The act stipulates that judges in second and third class cities, like San Carlos City, should receive a basic annual salary of ₱18,000. At the time of the petition, the petitioner was earning an annual salary of ₱12,000, substantially below the mandated amount.

Allegations and Claims Made by the Petitioner

Arenas claimed that the City had a duty to ensure that he received the appropriate salary differential as mandated by law, as it was the City’s obligation to provide such payments. He argued that the respondents had repeatedly failed to enact the necessary budget to pay this differential, totaling ₱9,500, which he claimed created a situation that obliged him to resort to legal action due to a lack of other remedies. He also mentioned incurring attorney's fees for the petition.

Respondents' Defense

In their response dated February 10, 1971, the respondents admitted some facts but denied the claims regarding the legislative duty to pay the salary difference. They argued that the payment of salary differences was discretionary based on the financial state of the city, which they claimed was facing severe budget issues. They indicated that the city judge’s salary was already set at ₱12,000, which was ₱100 less than that of the city mayor’s ₱13,200, aligning with the stipulations of Republic Act No. 5967.

Lower Court Decision

The Court of First Instance of San Carlos City dismissed the petition on May 31, 1971, stating that the Congress intent in enacting Republic Act No. 5967 was to ensure that a city judge’s salary should not exceed that of the city mayor. The Court noted that the statutory provision permitting the city government to determine the salary was integral to implementing such salary determinations.

Legislative Intent Interpreted

The Court highlighted discussions from Senate deliberations associated with the creation of Republic Act No. 5967, indicating that it was never the intent for city judges to earn more than mayors. C

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