G.R. No. 231298 . October 07, 2020.
ROBERTO A. ESTOCONING, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Roberto A. Estoconing, General Manager of the Silliman University Cooperative, was charged with violating the Expanded Senior Citizens Act ( Republic Act No. 9994 ) for repeatedly refusing to grant a 20% discount on soft drinks to senior citizen Manuel Utzurrum Jr. on eight separate occasions in 2011. Utzurrum, a cooperative member, presented his Senior Citizen ID each time but was denied the discount. He sent letters and pursued complaints through the Office of the Senior Citizen Affairs and the barangay, but no settlement was reached.
Estoconing pleaded not guilty, arguing that the cooperative, being registered under the Cooperative Development Authority and tax-exempt under the Philippine Cooperative Code ( Republic Act No. 9520 ), was exempt from the discount mandate. He also contended that granting the discount to Utzurrum, a member who receives an annual patronage refund, would violate the law’s prohibition on double discounts. The Municipal Trial Court in Cities convicted Estoconing, a ruling affirmed by the Regional Trial Court and the Court of Appeals.

ISSUE

Whether the Silliman University Cooperative, as a tax-exempt entity under the Philippine Cooperative Code, is obliged to grant the 20% senior citizen discount mandated by the Expanded Senior Citizens Act.

RULING

The Supreme Court DENIED the petition and AFFIRMED Estoconing’s conviction. The Court harmonized the provisions of the Philippine Cooperative Code and the Expanded Senior Citizens Act, ruling that the cooperative’s tax exemption does not absolve it from the social obligation to grant senior citizen discounts. The discount is a statutory privilege for senior citizens, not a tax liability that can be excused by a cooperative’s tax-exempt status. The law explicitly allows the discount to be claimed as a tax deduction, but this mechanism is merely a recovery option for taxable establishments; it is not a precondition for the grant of the discount itself. The cooperative’s obligation arises from its operation as a restaurant establishment selling food and drinks to the public, bringing it within the coverage of the senior citizen law. The Court emphasized that the discount is a social justice measure intended to benefit a vulnerable sector, and exemptions must be strictly construed against the grantee. Estoconing’s defense of potential business loss was deemed irrelevant, as the law imposes an unconditional duty to provide the discount.