Case Summary (G.R. No. 254757)
Factual Antecedents and Background
The SRA was established under Executive Order No. 18 issued by President Corazon Aquino in 1986. Subsequently, it was declared a government-owned and controlled corporation by Executive Order No. 631 in 2007. In 2011, Republic Act No. 10149, known as the "GOCC Governance Act of 2011," reinforced the financial viability and governance of GOCCs, which included the establishment of the GCG. The GCG's responsibilities included evaluating the performance of GOCCs and developing remuneration systems. In 2016, EO No. 203 was issued allowing for the establishment of a Compensation and Position Classification System (CPCS) and supporting the adoption of early retirement incentives.
The SRA's RATPLAN
To adapt to industry challenges, the SRA formulated the RATPLAN in 2015, increasing its plantilla positions and proposing a reorganization to enhance efficacy. The GCG subsequently approved this on April 12, 2016, with a specific focus on offering retirement and separation packages, as outlined in MO No. 2016-05. The SRA sought to implement the ERIP, inviting employees to participate, including the petitioners from whom separation was formalized on August 1, 2016.
Implementation Issues and Inaction
Despite the implementation schedule, the SRA encountered delays in releasing retirement benefits after seeking a supplemental budget from the DBM. A subsequent approval, however, excluded these benefits due to the absence of implementing guidelines for the EPCS. Consequently, while the SRA separated petitioners from service, the promised retirement benefits were not disbursed. The GCG advised holding back these payments until further guidelines could be established, which resulted in the petitioners being removed from the payroll.
Civil Service Commission Involvement
In 2017, several petitioners filed a complaint with the Civil Service Commission (CSC) alleging illegal dismissal due to the non-release of ERIP benefits, contending that their retirement was predicated on the ERIP’s implementation. Although the SRA argued successful compliance with retirement protocols, the CSC ultimately dismissed the complaint but noted that petitioners could pursue their claims before the appropriate forum, urging the SRA to expedite the benefits' release.
Subsequent Developments
Following the CSC’s decision, further attempts by petitioners to obtain their ERIP benefits went unanswered. They filed a complaint before the Ombudsman for non-compliance with the CSC’s directive and continued to seek implementation adjustments from the GCG. However, the GCG clarified that its authority to implement was restrained by EO No. 36, which suspended previous guidelines.
Petition for Mandamus
With continued delays in receiving their benefits, the petitioners resorted to filing a Petition for Mandamus, asserting their entitlement to the ERIP benefits, based on established legal right and procedural provisions. They argued that, under RA 10154, the government is mandated to release retirement benefits within 30 days following retirement.
Arguments and Legal Contentions
Petitioners impel
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Background and Factual Antecedents
- The Sugar Regulatory Administration (SRA) was created under Executive Order (EO) No. 18, series of 1986, to promote the growth and development of the sugar industry.
- EO No. 631, series of 2007, declared the SRA as a government-owned and controlled corporation (GOCC).
- Republic Act No. 10149 (GOCC Governance Act of 2011) created the Governance Commission for GOCCs (GCG) as a central policy-making and regulatory body overseeing GOCCs.
- EO No. 203, series of 2016, authorized the GCG to implement the Compensation and Position Classification System (CPCS) and permitted the grant of an Early Retirement Incentive Program (ERIP).
- Republic Act No. 10659 (Sugarcane Industry Development Act of 2015) was enacted to promote the competitiveness and development of the sugarcane industry.
The SRA Organizational Strengthening Rationalization Plan (RATPLAN)
- SRA formulated the RATPLAN in 2015 to strengthen its organizational structure and capacity in accordance with RA 10659.
- RATPLAN was approved by the GCG on April 12, 2016, through Memorandum Order No. 2016-05.
- Conditions for RATPLAN implementation included adoption and offering of the retirement and separation package using incentives under EO No. 203 and implementation within two months.
- SRA informed employees of RATPLAN approval and invited applications for the ERIP; petitioners availed themselves of this early retirement option.
- SRA secured Board Resolution No. 2016-142 for supplemental budget for payment of ERIP benefits and submitted to the DBM for approval.
- SRA separated petitioners effective August 1, 2016, but release of retirement benefits was withheld.
Issues Regarding the Release of Retirement Benefits
- GCG advised SRA to withhold payment pending issuance of implementing guidelines for EO No. 203.
- DBM did not approve supplemental budget for ERIP due to absence of implementing guidelines.
- EO No. 36, series of 2017, issued by President Duterte, suspended the CPCS, including the ERIP under EO No. 203.
- GCG issued MC No. 2017-03 to implement EO No. 36, further suspending the ERIP.
Actions Taken by Petitioners for Relief
- Petitioners filed a complaint for illegal dismissal and reinstatement with the Civil Service Commission (CSC) due to non-release of benefits.
- CSC dismissed the complaint but ruled the separation was not illegal given the voluntary nature of ERIP availed by petitioners.
- CSC directed the SRA to release the retirement benefits promptly; decision became final and executory in 2019.
- Petitioners submitted multiple letters to SRA, GCG, and the Office of the President for release of benefits, all ignored.
- Some petitioners filed a complaint before the Ombudsman for failure to comply with CSC decision.
- Petitioners also requested exclusion of ERIP from suspension under MC No. 2017-03; GCG responde