G.R. No. 51570 - Philippine Veterans Affairs Office vs. Segundo

Case Summary (G.R. No. 51570)

Relevant Dates and Procedural Posture

Key dates include the approval of pension (effective April 1947), cancellation (November 1, 1951), Del Mar decision (June 27, 1973), filing of the petition for mandamus by respondent (February 28, 1974), and the Supreme Court decision resolving the present appeal (August 15, 1988). The case reached the Supreme Court by certification from the Court of Appeals on pure questions of law.

Applicable Statutes, Regulations and Precedents

Governing law and authorities invoked include Republic Act No. 65, as amended (The Veteran’s Bill of Rights); Section 6 of Regulation No. 2 of the Veterans office (policy cancelling benefits where a similar U.S. benefit exists); Civil Code prescription rules (art. 1144, par. 2) and doctrine on accrual of causes of action; Supreme Court precedents Del Mar v. Philippine Veterans Administration (No. L-27299, June 27, 1973), Espanol v. Chairman, Philippine Veterans Administration (No. L-44616, June 29, 1985), and Board of Administration, PVA v. Agcaoili (No. L-38129, July 23, 1974). The decision also invokes constitutional policy concerning the State’s duty to provide social services and care to veterans (citing the 1973 Constitution).

Core Legal Issues Presented

Whether the respondent’s action to compel restoration of pension payments (effective from the date of cancellation in November 1951) was barred by prescription. 2) Whether Del Mar v. Philippine Veterans Administration governs the present case and, if so, whether its applicability is affected by prescription. 3) Whether mandamus was improper because no prior administrative demand was made and because of the Agcaoili ruling on payments from public funds.

The Court’s Analysis on Prescription

The Court adopted the analysis in Espanol: prescription under the ten-year rule (Civil Code, art. 1144, par. 2) cannot be counted from the date of the administrative cancellation in 1951 because that cancellation enjoyed presumptive validity until invalidated by judicial pronouncement. A cause of action accrues, and prescription begins to run, only when there exists (1) a right in favor of the plaintiff, (2) a corresponding duty on the defendant to honor that right, and (3) an act or omission in violation of that right for which relief is available. Because Section 6 of Regulation No. 2 retained presumptive validity until the Court’s ruling in Del Mar (June 27, 1973), the right to challenge continued cancellation and to seek restoration only accrued upon Del Mar’s invalidation of the rule. Therefore prescription began to run from June 27, 1973, and Mrs. Segundo’s petition filed February 28, 1974 was within the ten-year period.

Applicability of Del Mar and the Binding Effect of Supreme Court Decisions

The Court held Del Mar to be controlling precedent and applicable to both parties and non-parties affected by the invalid rule. It emphasized that Supreme Court interpretations of law or the Constitution form part of the legal system and are binding beyond the litigants in the original case; failure by the Veterans office to cease enforcement of a rule already held void would unjustifiably perpetuate an unlawful policy. The fact that Del Mar did not explicitly address prescription in that case does not negate its applicability here; Del Mar’s invalidation of Section 6 is the triggering event for accrual of the cause of action and thus for running of prescription.

Mandamus, Exhaustion of Administrative Remedies, and the Agcaoili Decision

The Court rejected the contention that mandamus was improper for lack of prior administrative demand. Relying on Espanol, it reiterated that when the case involves solely legal questions, exhaustion of administrative remedies is not required before seeking judicial relief. As to Agcaoili, which required appropriation before compelling payment of public funds, the Court distinguished the present case: Mrs. Segundo sought restoration of cancelled pension payments

Case Syllabus (G.R. No. 51570)

Facts of the Case

The respondent, Brigida V. Segundo, is the widow of the late Feliciano Segundo, a veteran of the Second World War, and she has remained unremarried.
Soon after her husband’s death, Brigida V. Segundo applied for pension benefits with the respondent institution then known as the Philippine Veterans Board (now the Philippine Veterans Affairs Office).
Her application for a monthly life pension was approved effective April 1947, subject to the conditions that she remain unremarried and that she not be the recipient of similar benefits from the U.S. Government.
In November 1951, the respondent cancelled and terminated Brigida Segundo’s monthly pension benefits on the ground that she was receiving a similar benefit from the U.S. Veterans Administration, in violation of the respondent’s standing policy (specifically, Section 6 of Regulation No. 2).
On June 27, 1973, the Supreme Court in Del Mar v. Philippine Veterans Administration (No. L-27299, 51 SCRA 340) declared the respondent’s policy (the provision cancelling benefits where the beneficiary receives similar U.S. benefits) null and void.
Despite the Del Mar decision, the respondent did not restore Brigida Segundo’s cancelled pension benefits.
The trial court issued an order (dated September 29, 1975, whose dispositive portion reconsidered and set aside an earlier order dated March 26, 1975) directing the respondent to pay the petitioner her monthly life pension effective November 1951 pursuant to Republic Act No. 65 and subsequent amendatory acts, subject to availability of appropriated funds, without pronouncement as to costs.

Procedural History

The case reached the Court of Appeals (CA), Sixth Division, CA-G.R. No. 04914-SP (Pascual, Crisolito, J., Sundiam, Carlos and Gorospe, Benjamin, JJ.). The Court of Appeals certified the case to the Supreme Court on the ground that it involves pure questions of law.
The respondent (Brigida V. Segundo) filed her petition on February 28, 1974.
The petitioner (The Philippine Veterans Affairs Office) appealed the trial court’s order, assigning three primary errors challenging the trial court’s judgment and the respondent’s entitlement to restoration of pension benefits.
The Supreme Court rendered its decision on August 15, 1988 (247 Phil. 330, G.R. No. 51570), dismissing the petition and ordering restoration of benefits.

Issues Presented (as assigned by Petitioner)

Whether the lower court erred in holding that the action to compel restoration of monthly pension effective from the date of cancellation in November 1951 had not prescribed.
Whether the lower court erred in holding that the Supreme Court’s decision in Del Mar v. Philippine Veterans Administration (June 27, 1973) is applicable in the instant case.
Whether the lower court erred in not dismissing the petition for mandamus for lack of cause of action because (a) no prior demand for restoration was made and there was no refusal to comply, and (b) because of the ruling in Board of Administration, Philippine Veterans Administration v. Agcaoili (G.R. No. L-38128, July 23, 1974) which allegedly bars relief absent an appropriation.

Petitioner’s Contentions (as framed in the record)

The petitioner contended that the respondent’s action had prescribed because the cancellation occurred in November 1951 and the prescriptive period runs from that date.
The petitioner contended that Del Mar is not applicable to the respondent’s case.
The petitioner argued that mandamus should be dismissed for lack of cause of action because no prior demand was made and there was no refusal to comply, and relied on the alleged principle from Agcaoili regarding claims for public funds and appropriations.

Applicable Statutes, Rules, and Precedents Cited in the Decision

Republic Act No. 65, as amended — The Veteran’s Bill of Rights (social legislation providing pension benefits).
Del Mar v. The Philippine Veterans Administration, No. L-27299, June 27, 1973, 51 SCRA 340 — holding Section 6 of Regulation No. 2 invalid.
Espanol v. Chairman, Philippine Veterans Administration, No. L-44616, June 29, 1985, 137 SCRA 314 — relied upon by the Court for prescription and administrative exhaustion principles.
Board of Administration, Philippine Veterans Administration v. Agcaoili, No. L-38129, July 23, 1974, 58 SCRA 72 — distinguished by the Court.
Civil Code, Art. 1144, par. 2 — on prescription/limitation (statute of limitations).
Civil Code, Art. 8 — on the binding character of Supreme Court interpretations as part of the legal system.
Sevarillos v. Hermosisima, 100 Phil. 501 (1956) — on the bi