G.R. No. 218097 . March 11, 2019.
GOVERNMENT SERVICE INSURANCE SYSTEM, PETITIONER, VS. APOLINARIO K. DAYMIEL, SUBSTITUTED BY HIS HEIRS, RESPONDENTS.

FACTS

Apolinario Daymiel retired from government service in 2003 after over three decades of employment. The GSIS initially computed his retirement benefits based on 33.65678 years of creditable service. However, GSIS later issued a re-computation, crediting him with only 23.85082 years, which substantially reduced his lump sum and monthly pension. This reduction was based on Policy and Procedural Guidelines No. 171-03 (PPG No. 171-03), approved by the GSIS Board in Resolution No. 90. The guideline stipulated that creditable service for benefit computation starts only from the date of actual remittance of monthly contributions, contrary to Republic Act No. 8291 (The GSIS Act), which states computation begins from the date of original appointment.
Daymiel filed a Petition for Declaratory Relief, Mandamus, and Damages before the Regional Trial Court (RTC), seeking to nullify the GSIS issuances and compel a proper computation. The RTC initially dismissed the case, citing GSIS’s primary jurisdiction under Section 30 of R.A. No. 8291 , which grants the GSIS original and exclusive jurisdiction to settle disputes arising from laws it administers. On appeal, the Court of Appeals reversed the RTC, declared PPG No. 171-03 and Resolution No. 90 null and void for lack of publication, and ordered GSIS to recompute benefits from Daymiel’s 1969 appointment date.

ISSUE

Whether the regular courts have jurisdiction over the subject matter of the case, which involves a challenge to the validity of a GSIS issuance and the computation of retirement benefits.

RULING

The Supreme Court ruled that the regular courts have jurisdiction. The Court clarified the distinction between the doctrine of primary jurisdiction and a court’s jurisdiction over the subject matter. Primary jurisdiction applies when a case involves technical questions or issues demanding administrative expertise, requiring prior recourse to the administrative agency. However, jurisdiction over the subject matter is conferred by law. The Court held that Daymiel’s petition was primarily one for declaratory relief, which is within the general jurisdiction of the RTC. The core issue was the validity of PPG No. 171-03—a question of law concerning whether an administrative issuance contravenes a statute and whether it is invalid for non-publication. This is a judicial question beyond the GSIS’s specialized competence. The GSIS’s quasi-judicial power under Section 30 of R.A. No. 8291 pertains to disputes over the application of existing laws and rules, not to challenges regarding the validity of its own rules, especially when they are alleged to contravene the very law they seek to implement. Since the petition directly assailed the validity of the guideline for being contrary to R.A. No. 8291 and for lack of publication, the RTC correctly assumed jurisdiction. The Court affirmed the CA’s decision nullifying the unpublished issuances and ordering a recomputation based on the statutory standard.