Case Summary (G.R. No. 88979)
Petitioner
Lydia O. Chua: Appointed initially as an emergency laborer in December 1974; served successively in four NIA-administered irrigation and watershed projects until project completion on December 31, 1988. Classified as co-terminous with the project, she held permanent status as Personnel Assistant A from July 9, 1982 to December 31, 1988.
Respondents
- Civil Service Commission: Denied early retirement benefits, interpreting RA 6683 coverage to exclude contractual and co-terminous personnel unless on regular, casual, temporary, or emergency status as of enactment date.
- National Irrigation Administration and Department of Budget and Management: Aligned with CSC’s interpretation; characterized petitioner’s service as project-based, non-career, and thus ineligible.
Key Dates
• December 2, 1988 – Enactment of RA 6683
• January 30, 1989 – Petitioner’s application for benefits filed
• March 17, 1989 – NIA denial of application
• April 25, 1989 – Petitioner’s reconsideration request denied by CSC
• February 7, 1992 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution – Equal Protection Clause (Art. III, Sec. 1)
• Republic Act No. 6683 – Grants early retirement and voluntary separation benefits to regular, temporary, casual, and emergency national government employees with at least two consecutive years of service; excludes AFP uniformed personnel.
• Joint DBM-CSC Circulars Nos. 88-1 and 89-1 – Implement coverage and exclusions under RA 6683.
• CSC Memorandum Circulars Nos. 11, 39, and 14 (1990-1991) – Define non-career service categories, co-terminous status, and creditable service for retirement eligibility.
Issue
Whether personnel whose tenure is co-terminous with a special, time-bound government project qualify for early retirement benefits under RA 6683.
Facts
• Chua rendered nearly 15 years of continuous service under successive World Bank–funded irrigation projects, culminating in permanent appointment status co-terminous with project life.
• RA 6683’s Sec. 2 covers “all regular, temporary, casual and emergency employees” with two consecutive years of service as of separation date.
• Respondents maintained that “contractual,” “co-terminous,” or project staff are excluded despite similar service records.
Ruling
The Supreme Court granted the petition. It held that exclusion of co-terminous personnel from RA 6683 benefits was unjustified and violated equal protection. Petitioner’s application for early retirement benefits must be favorably disposed in accordance with RA 6683.
Legal Reasoning
- Classification and Coverage
• RA 6683 expressly extends benefits to regular, temporary, casual, and emergency employees without excluding co-terminous staff.
• The doctrine of expressio unius est exclusio alterius cannot defeat constitutional guarantees when similarly situated employees are treated unequally. - Equal Protection
• Under Art. III, Sec. 1 of the 1987 Constitution, classifications must rest on substantial distinctions germane to legislative purpose.
• Co-terminous personnel, like casual and temporary employees, share identical disabilities (lack of plantilla, transience) yet casual employees are covered. Denying co-terminous staff equal benefits violates equal protection. - Doctrine of Necessary Implication
• Statutory purpose of RA 6683—to streamline bureaucracy by inducing voluntary separations—embraces all service categories rendering two years of continuous government service.
• Legislative history and pending amendments confirm intent to cover contractual and project personnel, provided they meet service requirements. - Adm
Case Syllabus (G.R. No. 88979)
Facts of the Case
- Republic Act No. 6683, approved December 2, 1988, provides benefits for early retirement, voluntary, and involuntary separation to streamline the bureaucracy.
- Coverage per Sec. 2: all appointive officials and employees of the National Government (including GOCCs with original charters) and all LGU personnel; applies to regular, temporary, casual, and emergency employees with at least two consecutive years of service as of separation; excludes uniformed AFP/PC-INP.
- Lydia O. Chua, Personnel Assistant A at NIA’s Watershed Management & Erosion Control Project (WMECP), applied on January 30, 1989 for RA 6683 benefits.
- NIA denied her application, offering only involuntary separation benefits under general reorganization rules (½ month basic pay per year of service from 1980).
- CSC denied her appeal, holding that as of December 2, 1988 her appointment was contractual and “co-terminous” with the project, thus outside RA 6683’s coverage.
Petitioner’s Service Record
- December 2, 1974–March 1975: emergency laborer, NIA-Upper Pampanga River Project.
- March 24–August 31, 1975: temporary research aide, same project.
- September 1, 1975–December 31, 1976: temporary, NIA-FES III.
- January 1, 1977–May 31, 1980: temporary, NIA-UPR IIS DRD.
- June 1, 1980–July 8, 1982: temporary, NIA-WMECP; July 9, 1982–December 31, 1988: permanent status, co-terminous with WMECP.
Petitioner’s Arguments
- RA 6683 requires only two consecutive years of service for coverage, irrespective of appointment status.
- She held a permanent position in the Administrative Service and rendered almost 15 years of continuous service.
- Not excluded under Joint DBM-CSC Circular 88-1 exclusions (consultants,