G.R. No. 243133, March 8, 2023
REPUBLIC OF THE PHILIPPINES, THROUGH THE OFFICE OF THE SOLICITOR GENERAL, OFFICE OF THE SENIOR CITIZENS AFFAIRS (OSCA), DEPARTMENT OF SOCIAL WELFARE AND DEVELOPMENT (DSWD), PETITIONERS, VS. PRYCE CORPORATION, INC., RESPONDENT.

FACTS

The case involves the interpretation of Republic Acts No. 7432, 9257, and 9994, which grant a 20% discount to senior citizens on “funeral and burial services.” The specific issue is whether “interment services” are included within the scope of “funeral and burial services” for the purpose of availing the discount.

ISSUE

Whether “interment services” are included in the term “funeral and burial services” as used in the senior citizen discount laws, thereby entitling beneficiaries to the 20% discount.

RULING

Yes. The concurring opinion holds that “interment services” are included within the meaning of “funeral and burial services” for the purpose of the 20% discount. The opinion reasons that:
1. The laws are social justice and affirmative action measures meant to combat age-based discrimination and must be interpreted liberally to achieve their humanitarian purpose.
2. In ordinary usage, “funeral services” is an expansive term that includes services related to the final disposition of remains, such as interment or direct burial.
3. The terms “burial” and “interment” are synonymous in common usage and industry practice, both referring to the act of depositing a dead body in the earth or a tomb.
4. A restrictive interpretation excluding interment services would be unreasonable and contrary to the legislative intent of leveling the playing field for seniors, especially as geographical constraints (e.g., high water tables) may make entombment a necessary alternative to in-ground burial.
Therefore, the 20% discount extends to interment services.