G.R. No. L-30914. January 28, 1980.
LEONARDO ALCANTARA, as Deputy Register of Deeds of Batangas, petitioner, vs. HON. JUAN PONCE ENRILE, as Secretary of Justice; GREGORIO BILOG, JR., as Commissioner of Land Registration; COMMISSIONER OF CIVIL SERVICE; and the DIRECTOR OF CLASSIFICATION and COMPENSATION, respondents.

FACTS

Petitioner Leonardo Alcantara, the Deputy Register of Deeds of Batangas, sought to compel public officials to adjust his annual salary from P6,798 to P12,000 effective June 1, 1969. Republic Act No. 3674 , enacted in 1963, authorized the Secretary of Justice to periodically revise the salaries of Registers of Deeds and their Deputies based on a schedule tied to average collections, with a proviso that their pay should not be lower than that of the lowest provincial/city department head and assistant by more than P1,200. Pursuant to this law and the classification of Batangas as a first-class province, the Secretary issued Administrative Order No. 215, adjusting the Deputy Register’s salary to P12,000.
However, the Commissioner of Land Registration informed Alcantara that his salary would only be increased to P7,200, not P12,000. The Secretary of Justice upheld this limitation in an Opinion, invoking Section 9 of the Civil Service Law ( Republic Act No. 2260 , as amended), which set a maximum annual salary of P7,200 for holders of a second-grade civil service eligibility, which Alcantara possessed.

ISSUE

Whether petitioner Alcantara is entitled to the P12,000 salary adjustment under R.A. No. 3674 and Administrative Order No. 215, despite the salary ceiling for second-grade eligibilities under the general Civil Service Law.

RULING

The Supreme Court ruled in favor of Alcantara, granting the writ of mandamus. The legal logic centered on statutory interpretation and legislative intent. The Court found that R.A. No. 3674 was a special law enacted to specifically address and rectify the stagnant salary scales of Registers of Deeds and their Deputies, recognizing their increased workload and revenue collections. The explanatory note of the law’s precursor bill explicitly stated this intent to provide “simple justice” to this distinct class of officials.
The Court held that this special salary-adjustment mechanism under R.A. No. 3674 prevails over the general salary classification limits in the Civil Service Law. This conclusion was bolstered by the official stance of the Director of Classification and Compensation (head of WAPCO), who indicated that the position of Deputy Register of Deeds was considered exempt from the general government classification and pay plans by virtue of R.A. No. 3674 . Therefore, the P7,200 ceiling for second-grade eligibilities under Section 9 of R.A. No. 2260 applied only to positions within the WAPCO classification plan and did not control positions whose salaries were specifically governed by a separate, special statute like R.A. No. 3674 . Granting the adjusted salary was also deemed equitable, considering Alcantara’s long government service and the fact that a subordinate in his office had received a proportionately higher adjustment.