Case Summary (G.R. No. 218097)
Proceedings Before the RTC
The respondent filed a petition for declaratory relief, mandamus, and damages before the RTC. GSIS moved to dismiss for failure to state a cause of action and lack of subject-matter jurisdiction, invoking the GSIS Board’s exclusive quasi-judicial power under Section 30 of R.A. 8291. The RTC initially granted dismissal but reversed on reconsideration, finding the challenged issuances invalid for non-publication. After trial, however, the RTC on July 29, 2008 dismissed the petition, holding that GSIS had original and exclusive jurisdiction over disputes under R.A. 8291.
Court of Appeals Ruling
The CA reversed the RTC in its February 25, 2014 Decision, ruling that the petition was for declaratory relief under Rule 63 and within the RTC’s jurisdiction. It declared PPG 171-03 and Resolution No. 90 null and void for lack of publication and directed GSIS to recompute respondent’s benefits from original appointment. A subsequent GSIS motion for reconsideration was denied on April 28, 2015.
Issue: Jurisdiction Over Dispute
Whether a regular court may exercise jurisdiction to declare administrative issuances void for lack of publication and to determine the legal basis for retirement benefit computation, or whether such disputes fall exclusively within GSIS’s quasi-judicial domain under R.A. 8291.
Analysis on Jurisdiction
The Constitution and statutes confer jurisdiction; procedural rules cannot override substantive jurisdictional grants. R.A. 8291 Section 30 and IRR Sections 14.1, 14.3 vest original and exclusive quasi-judicial power in the GSIS Board to settle benefit disputes. The doctrine of primary jurisdiction permits deferral to administrative expertise in technical matters. However, when a petition seeks to invalidate administrative acts as contrary to law or unconstitutional, the regular courts have jurisdiction to exercise judicial review, as guaranteed by the Constitution.
Analysis on Nature and Validity of Issuances
Administrative rules are classified as interpretative or legislative. Legislative rules, which create new burdens or conditions not stipulated by statute, require publication before taking effect. PPG 171-03 and Resolution No. 90 set new conditions for the computation of GSIS benefits, departing from R.A. 8291’s “original appointment” standard. As legislative rules, they were subject to the publication requirement, which was not complie
Case Syllabus (G.R. No. 218097)
Relevant Antecedents
- On August 18, 1969, Apolinario K. Daymiel began service as a casual laborer at the Provincial Engineering Office of Zamboanga del Norte and later became Accounting Clerk III until retirement on July 1, 2003.
- Upon retirement, Daymiel applied for benefits from GSIS; a tentative computation initially credited him with 33.65678 years of service, yielding a lump sum of ₱542,325.00 and a monthly pension of ₱9,038.75.
- A subsequent re-computation under GSIS Policy and Procedural Guidelines No. 171-03 (PPG No. 171-03), approved by GSIS Board Resolution No. 90, reduced his credited service to 23.85082 years, lowering his lump sum to ₱384,295.80 and monthly pension to ₱5,886.77.
- Daymiel challenged the re-computation by letter and then filed a petition for declaratory relief, mandamus, and damages before the Regional Trial Court (RTC), arguing that PPG No. 171-03 conflicted with RA 8291, which defines the starting point for service credit as the date of original appointment, whereas PPG No. 171-03 used the date of contribution payment.
Proceedings Before the Regional Trial Court
- GSIS filed a Motion to Dismiss for failure to state a cause of action and lack of jurisdiction, citing RA 8291’s grant of original and exclusive jurisdiction to the GSIS Board to hear disputes.
- RTC Branch 8 initially granted the Motion to Dismiss on November 8, 2004, but reversed that resolution on February 10, 2005, holding PPG No. 171-03 and Resolution No. 90 invalid for lack of publication and declining to apply the doctrine of primary jurisdiction.
- GSIS answered the petition, and after trial on the merits, the RTC issued a decision on July 29, 2008 dismissing the petition for lack of jurisdiction under Section