This Supreme Court resolution emphasizes that the Department of Budget and Management (DBM) must adhere to the Court’s interpretation of laws, specifically concerning the grant of permanent total disability benefits to the heirs of deceased judges. The Court affirmed its authority to interpret laws and directed the DBM to release funds for these benefits, reinforcing the judiciary’s fiscal autonomy and administrative supervision over courts. This decision safeguards the financial security of judges’ families and underscores the separation of powers, preventing the DBM from overriding judicial interpretations.

Beyond the Budget: Upholding Judicial Authority in Granting Benefits to Deceased Judges’ Heirs

This case arose after the Department of Budget and Management (DBM) disallowed the five-year lump sum gratuity claimed by the heirs of the late Judge Melvyn U. Calvan and Judge Emmanuel R. Real. These gratuities were granted under the Supreme Court’s Resolution dated September 30, 2003, in A.M. No. 02-12-01-SC, which aimed to provide permanent physical disability benefits to the heirs of Justices and Judges who die in service. The DBM argued that Republic Act No. 910 treats death in actual service and retirement due to permanent physical disability as distinct circumstances, thus questioning the Supreme Court’s resolution.

The Supreme Court firmly addressed the issue of whether the DBM had the authority to disallow the release of funds based on its interpretation of Republic Act No. 910, as amended. The Court emphasized the constitutional principle of separation of powers, reiterating that it is the duty of the legislature to make the law, the executive to execute the law, and the judiciary to construe the law. The Court cited United States vs. Ang Tang Ho, which underscored that each branch of government is supreme within its jurisdiction, and it is solely the judiciary’s role to determine the constitutionality of legislative acts.

“[i]t is the duty of the Legislature to make the law; of the Executive to execute the law; and of the Judiciary to construe the law. The Legislature has no authority to execute or construe the law, the Executive has no authority to make or construe the law, and the Judiciary has no power to make or execute the law. Subject to the Constitution only, the power of each branch is supreme within its own jurisdiction, and it is for the Judiciary only to say when any Act of the Legislature is or is not constitutional”.

Building on this principle, the Supreme Court asserted its final authority in interpreting laws, stating that no other government agency, including the DBM, could exercise this constitutionally mandated function. The Court referenced Re: Retirement Benefits of the late City Judge Alejandro Galang, Jr., where it previously construed Republic Act No. 910 to include death in actual service within the ambit of “permanent physical disability,” echoing Justice Teehankee’s sentiment that “there is no more permanent or total physical disability than death.”

The Court addressed the gaps in Republic Act No. 910, particularly concerning situations where a Justice or Judge dies in service without meeting the twenty-year length of service requirement. It invoked the principle established in Floresca vs. Philex Mining Corporation, noting that courts “do and must legislate” to fill gaps in the law to prevent injustice, as legislators cannot foresee every possible scenario. The Supreme Court’s Resolution dated September 30, 2003, in A.M. No. 02-12-01-SC, was issued to address this gap, ensuring that the law’s purpose is achieved fairly.

“…even the legislator himself, through Article 9 of the New Civil Code, recognizes that in certain instances, the court, in the language of Justice Holmes, ‘do and must legislate’ to fill in the gaps in the law; because the mind of the legislator, like all human beings, is finite and therefore cannot envisage all possible cases to which the law may apply. Nor has the human mind the infinite capacity to anticipate all situations”.

The Court reiterated that its interpretation of a law becomes part of the law itself, citing People vs. Jabinal. As an interpretation of Republic Act No. 910, the Resolution dated September 30, 2003, became integral to the statute, binding the DBM to honor and execute it. The Court emphasized that the DBM, as an agency under the executive branch, is mandated to ensure faithful execution of all laws, including the Court’s resolution.

“[d]ecisions of this Court, although in themselves not laws, are nevertheless evidence of what the laws mean, and this the reason why under Article 8 of the New Civil Code, ‘judicial decisions applying or interpreting the laws or the Constitution shall form part of the legal system x x x.’ The interpretation upon a law by this Court constitutes, in a way, a part of the law as of the date the law was originally passed, since this Court’s construction merely establishes the contemporaneous legislative intent that the law thus construed intends to effectuate”.

The Supreme Court cautioned the DBM against overstepping its mandate. It clarified that while the DBM is responsible for ensuring disbursements are made in accordance with the law, this does not extend to reviewing the Court’s issuances or substituting them with its own interpretations. Such actions, the Court warned, constitute a blatant usurpation of judicial function and a disregard for constitutional boundaries.

The Court highlighted a prior instance in A.M. No. 11238-Ret where it cautioned the DBM to respect the law and operate within its authority. It reiterated that the DBM’s responsibility is to ensure the efficient use of government funds, not to review judicial branch issuances. The Court reminded the DBM that it lacks the power of judicial review and should address any perceived misapplication of budgetary laws with the Court before implementing its own interpretations.

In summary, the Supreme Court firmly directed the DBM to release the funds for permanent total disability benefits to the heirs of Judges Calvan and Real. This decision underscores the judiciary’s fiscal autonomy and reinforces the principle of separation of powers, preventing the executive branch from infringing upon the judicial interpretation of laws.

FAQs

What was the central issue in this case?	The central issue was whether the Department of Budget and Management (DBM) had the authority to disallow the release of funds for permanent total disability benefits to the heirs of deceased judges based on its interpretation of Republic Act No. 910.
What did the Supreme Court decide?	The Supreme Court ruled that the DBM did not have the authority to disallow the release of funds and must adhere to the Court’s interpretation of Republic Act No. 910, which includes death in actual service within the scope of “permanent physical disability.”
What is Republic Act No. 910?	Republic Act No. 910, as amended, provides for the retirement and other benefits of Justices and Judges. The law outlines the conditions and amounts of gratuities and benefits payable to judges and their heirs.
What is the significance of the separation of powers in this case?	The separation of powers doctrine ensures that each branch of government (legislative, executive, and judicial) has distinct and independent powers. In this case, the Court emphasized that the DBM (executive branch) cannot encroach upon the judiciary’s power to interpret laws.
What was the DBM’s argument for disallowing the benefits?	The DBM argued that Republic Act No. 910 treats death in actual service and retirement due to permanent physical disability as separate circumstances, and that the Supreme Court’s resolution expanded the law’s intent by treating them as one.
How did the Supreme Court address the DBM’s argument?	The Supreme Court cited its previous rulings and emphasized its authority to interpret laws. It clarified that its interpretation of Republic Act No. 910 includes death in actual service within the scope of “permanent physical disability,” filling a gap in the law.
What does the ruling mean for the heirs of Justices and Judges?	The ruling ensures that the heirs of Justices and Judges who die in actual service receive the permanent total disability benefits as intended by the Supreme Court’s resolution, providing them with financial security.
What is the DBM’s role in relation to court decisions?	The DBM is responsible for ensuring that government funds are disbursed in accordance with the law, but it must respect and implement the decisions and interpretations of the Supreme Court. It cannot substitute its own interpretation for that of the judiciary.
What action did the Court order the DBM to take?	The Court directed the DBM to release the amounts corresponding to the permanent total disability benefits to the heirs of the late Judges Melvyn U. Calvan and Emmanuel R. Real and to implement the Resolution dated September 30, 2003, in all similar cases.

This resolution reaffirms the judiciary’s role as the final arbiter of legal interpretation, reinforcing the importance of respecting the boundaries between different branches of government. The decision serves as a reminder to government agencies, like the DBM, to adhere to the Supreme Court’s directives and interpretations of the law, ensuring that the rights and benefits of judges and their families are protected.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: RE: RESOLUTION GRANTING AUTOMATIC PERMANENT TOTAL DISABILITY BENEFITS TO HEIRS OF JUSTICES AND JUDGES WHO DIE IN ACTUAL SERVICE, A.M. No. 02-12-01-SC, November 24, 2004