Case Summary (G.R. No. L-34676)
Legal Background
The legal context revolves around Commonwealth Act No. 186 and its amendments, as well as Republic Act No. 4134, which increased the salaries of members of Congress from P7,200.00 to P32,000.00 per annum. This salary increase, however, was subject to the provisions of the 1935 Constitution, primarily the prohibition against any increase in compensation for members of Congress during their term of office.
Case Details and Procedural History
Following the conclusion of his term, Ligot claimed retirement gratuity under Commonwealth Act No. 186 which requires a minimum of twenty years of continuous service for eligibility. A treasury warrant was initially issued in Ligot's favor, calculated based on the increased salary from Republic Act No. 4134. However, this warrant was not signed by Auditor Velasco pending clarification from the Auditor General regarding similar claims.
The Auditor General later denied Ligot's claim, reaffirming that the retirement gratuity for individuals whose terms ended on December 30, 1969, should be based on the salary of P7,200.00 per annum, the salary legally applicable during their service.
Legal Arguments and Decision
Ligot's appeal hinged on the assertion that since the salary increase to P32,000.00 became operative upon the expiration of his term, his retirement gratuity should reflect this higher rate. However, the Court dismissed this notion, emphasizing adherence to the constitutional prohibition against salary increases during the terms of incumbents.
The Court reiterated that allowing Ligot to claim a retirement gratuity based on an increased salary would essentially circumvent the constitutional restrictions intended to prevent salary inflation among current officials, thus defying Article VI, Section 14 of the 1935 Constitution.
Key Findings
- The law explicitly stipulated that salary increases for members of Congress could only take effect after the expiration of all terms of the Congress members who approved the increase.
- Ligot was legally entitled to only the P7,200.00 per annum figure during his terms, which remained consistent even after his retirement.
- Any retirement benefit derived from th
Case Syllabus (G.R. No. L-34676)
Case Overview
- The case concerns a petition for review filed by Benjamin T. Ligot, a former Congressman, contesting the decision of the Auditor-General regarding his retirement gratuity.
- The primary legal question revolves around the computation of Ligot’s retirement benefits based on his tenure and the applicable salary laws at the time of his retirement.
Facts of the Case
- Benjamin T. Ligot served as a Congressman for three consecutive terms from December 30, 1957, to December 30, 1969.
- During his second term, Republic Act No. 4134 was enacted, which increased the salaries of congressmen from P7,200.00 to P32,000.00 per annum, effective July 1, 1964.
- Ligot was not entitled to the increased salary during his third term, which ended on December 30, 1969, due to the constitutional provision that salary increases for Congress members could not take effect until after the expiration of the full terms of all approving members.
- After losing in the 1969 elections, Ligot filed for retirement benefits under Commonwealth Act 186, which stipulated that elected officials with at least twenty years of service were entitled to retirement gratuities.
Legal Issues
- The main issue was whether Ligot’s retirement gratuity should be computed based on the increased salary of P32,000.00 per annum or the former salary of P7,200.00 per annum, given that he did not receive t