Case Summary (A.M. No. 02-12-01-SC)
Background of the Case
Judge Melvyn U. Calvan served as the Presiding Judge of the Municipal Circuit Trial Court in Bangui, Ilocos Norte. He passed away on November 16, 2003, due to cardio-respiratory arrest, after 21 years and 2 months of government service, including 16 years in the Judiciary. His widow, Dr. Susana B. Calvan, sought benefits under Republic Act No. 910 as per the Court's Resolution dated September 30, 2003. Conversely, Judge Emmanuel R. Real, who served as the Presiding Judge of the Regional Trial Court in Ligao, Albay, died on February 25, 2002, from complications related to multiple myeloma, after 32 years and 7 months of service, including 10 years in the Judiciary. His family filed a claim for benefits, which initially faced denial but was later approved in alignment with the aforementioned Resolution.
Disallowance by DBM
The Department of Budget and Management (DBM), however, disallowed a portion of the claims regarding the additional five-year lump-sum gratuity benefits for both judges. Undersecretary Mario L. Relampagos indicated that the beneficiaries of judges who die while in actual service would only be entitled to a five-year lump sum gratuity as defined distinctly from benefits available for those who retire due to permanent physical disability.
Resolution of the Court's Authority
The Supreme Court held that the DBM lacked the authority to disallow the disbursement of benefits based on its interpretation of Republic Act No. 910. According to the Constitution, the Judiciary holds exclusive jurisdiction over the interpretation of the law, and its decisions are final and binding on other branches of government. The Court reaffirmed its position that interpretations it provides act as part of the law they seek to clarify.
Interpretation of the Law
The Court referred to its precedent from "In Re: Retirement Benefits of the late City Judge Alejandro Galang, Jr.," where it interpreted the term "permanent physical disability" to include cases of death while in service. The Court identified a gap in the law concerning judges who died without fulfilling the full 20-year service requirement for retirement benefits, prompting the issuance of its earlier resolution on September 30, 2003, which the DBM is mandated to adhere to.
Directive to DBM
The Court's resolution directed the DBM to release t
...continue readingCase Syllabus (A.M. No. 02-12-01-SC)
Background of the Case
- This administrative matter originates from correspondence received by the Honorable Chief Justice from Undersecretary Mario L. Relampagos of the Department of Budget and Management (DBM).
- The letters informed the Court of DBM's decision to disallow a 5-year lump sum gratuity claimed by the heirs of the late Judges Melvyn U. Calvan and Emmanuel R. Real.
- This decision was based on the Court's earlier Resolution dated 30 September 2003 in A.M. No. 02-12-01-SC.
Legal Framework
- The Court's Resolution was issued under its fiscal autonomy and administrative supervision mandates as stated in Sections 3 and 6 of Article VIII of the Constitution.
- It authorized the granting of lump sum Permanent Physical Disability benefits to the heirs of Justices and Judges who die in actual service, with specific exclusions such as suicide or situations where the judge is the proximate cause of their own death.
Case of Judge Melvyn U. Calvan
- Judge Calvan served as the Presiding Judge of the Municipal Circuit Trial Court in Bangui, Ilocos Norte.
- He passed away on 16 November 2003 due to cardio-respiratory arrest after serving 21 years, 2 months, and 1 day in government service, of which 16 years, 3 months, and 6 days were in the Judiciary.
- His widow, Dr. Susana B. Calvan, requested benefits under Republic Act No. 910 on 12 Febr