Case Summary (G.R. No. 186560)
Background of the Case
Fernando P. de Leon, who served for 44 years, retired as Chief State Prosecutor of the Department of Justice (DOJ) in 1992, applying for retirement benefits under Republic Act (R.A.) No. 910. Initially approved by GSIS, his pension payments were halted in 2001 after a directive from the Department of Budget and Management (DBM) indicated that the law only applied to judges, failing to recognize his eligibility despite the precedent supporting non-judges' inclusion.
Events Leading to Discontinuation of Benefits
De Leon was reportedly unaware of the cancellation of his pension until late 2007 when he received a notification from GSIS, which cited a lack of appropriations for his pension due to his purported ineligibility under R.A. No. 910. Consequently, he filed a petition for mandamus in the Court of Appeals (CA) to compel GSIS to resume his pension payments and cover unpaid benefits since 2001.
Court of Appeals Decision
On October 28, 2008, the CA ruled in favor of De Leon, ordering GSIS to pay his adjusted monthly pension as per applicable laws other than R.A. No. 910 and to address back payments owed. The CA emphasized GSIS's initial approval of De Leon's retirement under R.A. No. 910, stating that an error in retirement classification should not preclude his entitlement to benefits under other laws.
GSIS's Arguments Against the CA Decision
GSIS contended that the CA erred by issuing the writ of mandamus without establishing a clear legal right on the part of De Leon. It claimed that the refund of De Leon's premium payments due to his retirement under R.A. No. 910 severed any nexus for benefits. Furthermore, GSIS argued that paying De Leon under a different retirement scheme would lead to unjust enrichment, overlooking the fact that retirement benefits are owed as a right.
Respondent’s Counterarguments
De Leon maintained that he met the eligibility requirements under both R.A. No. 660 and P.D. No. 1146 for retirement benefits and asserted that he could either remand premium contributions or accept deductions from future benefits. He further stressed that the improper interruption of his pension constituted a violation of his rights.
Supreme Court's Rationale
The Supreme Court found the procedural objections raised by GSIS unpersuasive, reinforcing the principle that courts may relax procedural rules to serve substantive justice. The Court noted that retirement laws must be interpreted liberally in favor of retirees to fulfill their purpose of providing sustenance post-service.
Legal Entitlements Established
The Court ruled that despite De Leon's erroneous classification under R.A. No. 910, he was entitled to retirement benefits under either R.A. No. 66
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Case Overview
- The case concerns a Petition for Review on Certiorari filed by the Government Service Insurance System (GSIS) seeking the nullification of the Decision dated October 28, 2008, and the Resolution dated February 18, 2009, of the Court of Appeals (CA) in CA-G.R. SP No. 101811.
- Respondent Fernando P. de Leon, a retired Chief State Prosecutor, applied for retirement benefits under Republic Act (R.A.) No. 910 but faced cancellation of his pension after receiving benefits for nine years.
Background of the Case
- Fernando P. de Leon retired from the Department of Justice (DOJ) in 1992 after 44 years of service and applied for retirement benefits under R.A. No. 910, which equated the rank of chief state prosecutors with judges.
- His retirement application was approved by GSIS, and he received his monthly pension from 1992 until 2001, when payments were halted due to DBM’s assertion that he did not qualify for retirement under R.A. No. 910.
- GSIS informed de Leon that he should not have retired under R.A. No. 910 and suggested seeking benefits under other laws.
Legal Proceedings
- Following the cessation of his pension, de Leon filed a petition for mandamus against GSIS, seeking to compel the continuation of his pension payments and the payment of back benefits.
- The CA granted the petition, ruling that GSIS must continue paying de Leon's pension under applicable laws, regardless of the erroneous application of R.A. No. 910.
Court of Appeals’ Findings
- The CA noted that GSIS allowed de Le