G.R. No. L-39743, September 24, 1983
Justiniano Cajiulat, et al., Petitioners, v. Honorable Ismael Mathay, Sr., in his capacity as Acting Chairman of the Commission on Audit, Respondent.

FACTS

The petitioners were permanent officials and employees of the Rice and Corn Administration (RCA), which was abolished by Presidential Decree No. 4. Prior to the abolition, they had already opted to retire under the Optional Retirement Law (Commonwealth Act No. 186, as amended) and had received the corresponding retirement gratuity provided therein. Following the issuance of PD No. 4, they filed a claim for an additional separation gratuity under Section 26, paragraph 3 of the same decree. This provision stated that permanent RCA employees who opt to retire, if qualified, “shall be given gratuity equivalent to one month salary for every year of service… in addition to all other benefits to which they are entitled under existing laws and regulations.”
The respondent Acting Chairman of the Commission on Audit denied their claim. He held that there was no legal basis for granting them a second gratuity for the same government service. The petitioners thus filed this petition, arguing that the denial rendered the specific clause in PD No. 4 meaningless, contrary to rules of statutory construction that every part of a law should be given effect.

ISSUE

Whether the petitioners, having already received retirement gratuity under the general Optional Retirement Law, are entitled to an additional separation gratuity under Presidential Decree No. 4.

RULING

The Supreme Court denied the petition and affirmed the decision of the Commission on Audit. The Court held that the petitioners are not entitled to double gratuity. The legal logic is anchored on the established state policy against double pension or gratuity for the same service. For an exception to this general policy to be valid, the law must provide for it in clear and unequivocal language. The phrase “in addition to all other benefits” in PD No. 4 does not meet this stringent test.
The Court explained that this clause merely ensures that retirees receive other standard benefits receivable under general laws, such as the refund of retirement contributions and the monetized value of accumulated leave credits. It was not intended to authorize a second, separate gratuity payment for the identical period of service. To interpret it otherwise would be an act of “over-liberality” and would violate the fundamental rule, as stated in Borromeo v. Government Service Insurance System, that pension laws should be interpreted to prevent double compensation unless expressly provided. The burden was on the petitioners to prove they belonged to an exempt class, which they failed to do. The general language of PD No. 4 cannot overcome the clear policy against double benefits.