AI-generated
Updated 21st February 2025
Arenas vs. City of San Carlos (Pangasinan)
This case involves Isidro G. Arenas, the City Judge of San Carlos City, who filed a petition for mandamus to compel the city government to pay his salary differential as mandated by Republic Act No. 5967. The Supreme Court dismissed his petition, affirming the lower court's ruling that the salary of a city judge should not exceed that of the city ma

Primary Holding

The Supreme Court held that the proviso in Republic Act No. 5967, which states that a city judge's salary must be at least P100 less than that of the city mayor, qualifies the general provision establishing city judges' salaries.

Background

Isidro G. Arenas, serving as City Judge of San Carlos City, claimed entitlement to a higher salary based on Republic Act No. 5967. The city government refused to pay the differential, citing that the law mandates the judge's salary to be lower than the mayor's. Arenas filed a mandamus petition, which was dismissed by the Court of First Instance.

History

  • Filed in the Court of First Instance of Pangasinan (Civil Case No. SCC-182)

  • Decision rendered on May 31, 1971, dismissing the petition

  • Supreme Court decision dated April 5, 1978, affirming the lower court’s ruling

Facts

  • 1. Arenas received an annual salary of P12,000, while the city mayor received P13,200.
  • 2. Republic Act No. 5967 set the basic salary of city judges in second and third class cities at P18,000 annually.
  • 3. The city government refused to pay the salary differential, citing financial difficulties and the legal requirement that a judge's salary must be less than the mayor's.

Arguments of the Petitioners

  • 1. Republic Act No. 5967 entitles him to a salary of P18,000 annually.
  • 2. The last proviso should not negate the primary intention of the law to increase judges' salaries.
  • 3. The refusal to pay violates his legal rights under the statute.

Arguments of the Respondents

  • 1. The proviso mandates that a city judge's salary must be at least P100 less than the mayor's.
  • 2. Financial constraints prevent the city from paying the differential.
  • 3. Compliance with the law is discretionary for the city government.

Issues

  • 1. Whether the city government is legally obligated to pay the salary differential to the petitioner.
  • 2. How to reconcile the general provision and the proviso in Republic Act No. 5967 regarding judges' salaries.

Ruling

  • 1. The petition was dismissed. The Supreme Court affirmed that the proviso qualifies the general provision, ensuring that city judges' salaries are lower than mayors'.
  • 2. Legislative intent, as reflected in congressional records, emphasized maintaining this salary hierarchy for public administration coherence.

Doctrines

  • 1. Statutory Construction Doctrine: A proviso qualifies the preceding general provision.
  • 2. Legislative Intent Doctrine: The latest legislative expression, especially in provisos, reflects the controlling legal intent.

Statutory and Constitutional Provisions

  • 1. Republic Act No. 5967, Section 7