Case Summary (A.M. No. 747-RET)
Applicable Law
The relevant legislation includes Republic Act No. 910, as amended, which outlines the retirement benefits for judges and justices. The key provisions are Section 1, which sets conditions for entitlement to a pension upon retirement, and Section 3, which deals with benefits for those retiring due to permanent disabilities, providing a lump sum for ten years but excluding further monthly annuity benefits.
Application for Disability Retirement
Justice Martin underwent a stroke that caused significant permanent physical impairments and was granted a disability retirement. The Supreme Court En Banc approved his disability retirement, certifying his permanent incapacity due to the cerebral stroke and authorizing the remittance of a gratuity equivalent to ten years of his salary.
Subsequent Request for Lifetime Pension
Eleven years post-retirement, Martin filed for a lifetime pension based on the premise that he had "earned a vested right" to it due to his age and service in the judiciary. He asserted that even though he initially opted for disability retirement, he should still qualify for a lifetime pension since he asked for benefits under Section 3.
Court's Initial Denial
On November 21, 1989, the Supreme Court denied Martin's request for a lifetime pension, reiterating the explicit provision in Section 3 stating that those retiring due to permanent disability would only receive a lump sum for ten years with no additional monthly pension for life.
Motion for Reconsideration and Liberal Interpretation
In response to the initial denial, Martin filed a motion for reconsideration. The Supreme Court engaged in further deliberation and indicated a need for a liberal interpretation of the law. The Court highlighted that retirement laws should primarily benefit retirees and that doubts should favor the individual rather than the state.
Final Decision and Entitlement
The Supreme Court ultimately granted Martin's motion for reconsideration. It reasoned that if a retiree could have qualified for a lifetime pension but instead elected for disability retirement, they should not be deprived of future benefits if they survived the
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Background of the Case
- Ruperto G. Martin, a former Associate Justice of the Supreme Court, suffered a cerebral stroke on January 1, 1978, at the age of 64 years, 9 months, and 13 days.
- He was born on March 27, 1913, and was two months and 17 days short of reaching the compulsory retirement age of 65 years on March 27, 1978.
- The 1973 Constitution, which was amended on January 30, 1980, had stipulated the compulsory retirement age for judges as 70 years.
- Martin applied for disability retirement under Section 3 of Republic Act (RA) 910, which was approved by the Court En Banc on January 10, 1978.
Medical Condition and Retirement Approval
- The Court's resolution acknowledged Martin's medical condition based on certificates from his attending physician and the Chief of Clinics of the Court, indicating that he suffered from permanent disability due to a cerebral stroke.
- The resolution included:
- Approval of Martin's application for permanent disability retirement benefits.
- Certification of his permanent physical disability incurred during his incumbency before the compulsory retirement date.
- Authorization for payment of a gratuity equivalent to ten years' salary with no further monthly annuity for the rest of his life.
Length of Service and Gratuity Payment
- Justice Martin had a total of 22 years and 5 months of service in the government, with over 11 years in the judiciary.
- He received a one-time lump sum retirement gratuity of P624,000, as