Case Summary (G.R. No. 243133)
Issue Presented
Whether interment services fall within the statutory phrase “funeral and burial services” for senior-citizen discount purposes under RA 7432, as amended by RA 9257 and RA 9994.
Nature and Scope of Declaratory Relief
The Court reaffirmed that declaratory relief (Rule 63) resolves questions of statutory construction or validity before actual breach, provided there is a justiciable controversy, ripeness, and no adequate alternate remedy. All requisites were met here, as respondent faced inevitable, adverse demands to grant the discount on its interment services.
Statutory Text and IRR Provisions
• RA 9257 and RA 9994 each grant a 20% discount “on funeral and burial services for the death of senior citizens.”
• IRR of RA 9257 lists related services without an exclusive limitation.
• IRR of RA 9994 defines “funeral and burial services” to cover casket/urn purchase, embalming, cremation, viewing/wake, morgue pickup, transport to burial site, and “other related services,” specifically excluding only obituary publication and memorial-lot cost.
Principles of Interpretation
• Statutory words bear their ordinary meaning absent clear contrary intent.
• Regulations cannot amend or narrow a law’s coverage beyond legislative intent.
• Ambiguities in social-welfare laws must be construed liberally in favor of beneficiaries.
Analysis and Rationale
- “Burial” and “interment” are commonly synonymous: both denote the final disposition of human remains, whether in earth, crypt, or mausoleum.
- The IRR’s phrase “and other related services such as” introduces illustrative, not exhaustive, examples, thereby encompassing interment services.
- Exclusions in the IRR list (obituary publication, memorial-lot cost) omit interment, evidencing no legislative or regulatory intent
Case Syllabus (G.R. No. 243133)
Facts of the Case
- Pryce Corporation, Inc. (respondent) is a domestic corporation selling memorial lots and offering interment services.
- On October 29, 2015, respondent filed a special civil action for declaratory relief (Civil Case No. CV-ORD-2015-215) before the Regional Trial Court (RTC) of Misamis Oriental, Cagayan de Oro City.
- Respondent sought a judicial construction of Section 4(a) of RA 7432 (as amended by RA 9257 and RA 9994) to determine whether “interment services” fall within the statutorily mandated 20% discount on “funeral and burial services” for senior citizens.
- Respondent contended that interment services were not explicitly included in the law or its Implementing Rules and Regulations (IRR) and thus are not subject to the discount.
Procedural History
- RTC Branch 17, in its January 18, 2018 Resolution, ruled that the petition for declaratory relief was properly filed and that “funeral and burial services” under the IRR did not include interment services.
- RTC denied petitioners’ motion for reconsideration in its October 22, 2018 Resolution.
- Petitioners (Republic of the Philippines, Office of the Solicitor General, OSCA, DSWD) filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court before the Supreme Court.
Issue
- Whether interment services are covered by the 20% discount on “funeral and burial services” granted to senior citizens under RA 7432, as amended by RA 9257 and RA 9994.
Ruling of the Regional Trial Court
- Found all requisites for a declaratory relief action present.
- Strictly construed the IRR of RA 9994 (Section 6) as listing only purchase of casket or urn, embalming, cremation cost, viewing or wake cost, hospital-morgue pick-up, and transport to place of origin.
- Excluded digging the grave, concreting, and other interment services from the scope of the 20% discount.
Parties’ Contentions
- Petitioners:
- The statutory phrase “funeral and burial services” is plain and unambiguous and must be understood in its ordinary