Title
NAPOLCOM vs. De Guzman, Jr.
Case
G.R. No. 106724
Decision Date
Feb 9, 1994
Dispute over retirement age of former Philippine Constabulary members under RA 6975; SC ruled Section 89's transition period applies only to local police, upholding compulsory retirement at 56 for PC members.

Case Summary (G.R. No. 106724)

Petitioner’s Claim and Administrative Action

Under Section 39 of RA 6975, petitioners issued notices of compulsory retirement to private respondents—former Philippine Constabulary (PC) officers—who had attained age fifty‑six (56). Petitioners maintained that Section 39’s compulsory retirement age of fifty‑six was applicable to those former PC officers, and that the four‑year transition scheme in Section 89 did not apply to them.

Respondents’ Claim and Reliance on Section 89

Respondents filed a declaratory relief action (Civil Case No. 91‑3498) arguing that Section 89’s transitory retirement schedule applied to members of the INP, and that the term “INP” in Section 89 includes former PC members because PD 765 had earlier constituted the Integrated National Police with the PC as its nucleus. They contended this transitory scheme governed retirement ages during the four‑year transition following RA 6975’s effectivity.

Key Dates and Procedural History

RA 6975 took effect on January 2, 1991. Respondents filed suit on December 19, 1991. The trial court issued a temporary restraining order on December 23, 1991, and a writ of preliminary injunction on January 8, 1992 upon bond. The regional trial court rendered judgment on August 14, 1992 holding Section 89 applicable to all present PNP members; petitioners filed the instant petition on October 8, 1992. The Supreme Court decision was rendered in 1994; the 1987 Constitution is the governing charter for analysis.

Applicable Statutory Provisions and Related Laws

Primary statutes at issue: RA 6975 (Sections 23, 39, 85, 86, 89, 90). Section 39 prescribes compulsory retirement at age fifty‑six, with limited one‑year retention for certain high ranks. Section 89 provides a four‑year transitional retirement schedule using the term “INP” with staggered ages (60, 59, 58, 57) for each consecutive year of the transition. Relevant antecedent law: PD 765 (establishing the Integrated National Police with the PC as nucleus) and PD 1184 (governing retirement age for local police at sixty). The Court also cited precedents on statutory construction and classification.

Trial Court Ruling and Rationale

The regional trial court declared that the term “INP” in Section 89 covered all members of the present PNP irrespective of their prior status and that Section 39 would only become operative after the four‑year transition. The trial court relied on PD 765’s characterization of the PC as the principal component of the INP and found ambiguity in RA 6975’s use of “INP,” declining to accept legislative explanations offered by petitioners.

Petitioners’ Arguments Before the Supreme Court

Petitioners argued that RA 6975 itself distinguishes between the PC and the INP in multiple provisions (Sections 23, 85, 86, and 90), and that Section 89’s transitory scheme was intended to address the local police forces formerly governed by PD 1184 and not the PC, which was already subject to a fifty‑six retirement age under AFP law. Petitioners urged that the plain statutory scheme and legislative history support excluding former PC members from Section 89’s four‑year transition.

Respondents’ Arguments Before the Supreme Court

Respondents maintained that the term “INP” in Section 89 should be read to include former PC members since PD 765 designated the PC as the nucleus of the INP and Section 89 did not expressly exclude the PC. They contended the trial court correctly applied Section 89 to all PNP members during the transition.

Statutory Construction Principles Applied by the Court

The Court reviewed statutory text and context, giving weight to internal statutory distinctions and to legislative history where ambiguity exists. It reiterated established canons: courts may examine prior laws on the same subject and legislative deliberations to ascertain intent when doubt arises, and should avoid literal constructions that conflict with legislative purpose.

Legislative History and Bicameral Conference Committee Evidence

The Supreme Court examined the Bicameral Conference Committee deliberations and found explicit statements by legislators indicating that Section 89’s transition schedule was aimed at the civilian/local police who previously retired at age sixty, while the PC’s retirement age of fifty‑six was to remain unchanged. Extracts from the Conference Committee showed members’ intent to preserve the PC’s fifty‑six retirement age and to phase down the local police retirement age from sixty to fifty‑six over the four‑year transition.

Court’s Analysis on the Meaning of “INP”

The Court concluded that “INP” in Section 89 was not synonymous with “PC” for purposes of the transitional retirement provision. Statutory provisions (Sections 23, 85, 86 and 90) manifest a distinction between the PC and the INP within RA 6975’s scheme, and the legislative records confirmed the drafters’ intent to confine Section 89’s transitory benefits to the local police component, not to former PC officers.

Equal Protection and Classification Test

Addressing potential equal‑protection concerns, the Court applied the Four‑Part test for valid legislative classification: (1) subs

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