Case Summary (G.R. No. 160568)
Background on Terminal Leave Benefits
Respondent Hermogenes P. Pobre had previously received terminal leave pays totaling P365,522.60 from his first two retirement incidents. For his third retirement from the PRC, however, Pobre sought to compute his terminal leave benefits based on his highest monthly salary as PRC chairman, dating back to 1958, the start of his government service as a budget examiner. This claim is grounded in Section 13 of Commonwealth Act 186, which provides the framework for calculating retirement benefits based on aggregate years of service across multiple positions in the government.
Initial Resolutions by the CSC
Doubts regarding the legality of Pobre's claims prompted the successor chairperson of the PRC, Antonieta Fortuna-Ibe, to consult the CSC and the Commission on Audit (COA). On October 29, 2001, the CSC issued Resolution No. 01-1739, concluding that Pobre was entitled only to terminal leave benefits accrued since his appointment as PRC chairman, excluding leave credits from his previous positions. Pobre sought reconsideration, leading to the issuance of Resolution No. 02-0236 on February 19, 2002, which partially modified the prior resolution to include service as PRC associate commissioner.
Appeal to the Court of Appeals
Dissatisfied with the CSC’s resolutions, Pobre elevated the matter to the Court of Appeals, presenting two primary issues: (1) whether the CSC had jurisdiction over his claim for terminal leave benefits while it was also under consideration by the COA, and (2) whether terminal leave benefits for a retiree serving in multiple government agencies could be computed based on overall service since initial employment, similar to the provisions under Commonwealth Act 186.
Decision by the Court of Appeals
In its decision dated March 31, 2003, the Court of Appeals ruled in favor of Pobre by annulling the CSC’s resolutions and asserting that the COA had jurisdiction over disputes regarding claims for terminal leave benefits. The Court ordered the parties to await the COA's determination regarding Pobre's claim before proceeding further. This decision was premised on the conclusion that the matter of auditing funds and expenditures related to terminal leave benefits falls within the COA's exclusive sphere of authority.
Petitioner’s Arguments on Reconsideration
Following the adverse ruling, the CSC filed a motion for reconsideration which was denied on September 24, 2003. The CSC continued to assert that it had jurisdiction to determine the legality of Pobre's claim, relying on its mandate under the 1987 Administrative Code. It cited a range of powers encompassing the administration of retirement programs and oversight of benefit implementations.
Jurisdictional Authority of the COA and CSC
The Court underscored the delineated powers of both the CSC and the COA, referencing the mandates established under Article IX-D of the 1987 Constitution. The COA's responsibilities include auditing and settling all government accounts, including expenditures related to
...continue readingCase Syllabus (G.R. No. 160568)
Case Overview
- This case involves a petition for review on certiorari filed by the Civil Service Commission (CSC) against Hermogenes P. Pobre regarding the computation of terminal leave benefits.
- The petition seeks to reverse the decision of the Court of Appeals dated March 31, 2003, which annulled CSC's resolutions on Pobre's terminal leave benefits.
- The case was decided by the Supreme Court on September 15, 2004.
Background of the Respondent
- Hermogenes P. Pobre is a former government official who has retired from government service three times.
- His first retirement was as commissioner of the Commission on Audit (COA) on March 31, 1986.
- He reentered government service and retired as chairman of the Board of Accountancy on October 31, 1990.
- Pobre's final retirement was as chairman of the Professional Regulation Commission (PRC) on February 17, 2001.
- He received terminal leave pay during his first two retirements, totaling P365,522.60.
Claim for Terminal Leave Benefits
- Upon his third retirement, Pobre claimed terminal leave benefits based on the highest monthly salary as PRC chairman, calculated from his original appointment in 1958.
- He invoked Section 13 of Commonwealth Act 186, which pertains to the computation of service for retirement benefits.
CSC Resolutions
- Doubting the legality of Pobre's claim, the successor PRC chairperson sought opinions from the CSC and COA.
- On October 29, 2001, CSC issued Resol