Philippine Veterans Affairs Office vs. Segundo

The prescriptive period for an action to restore cancelled pension benefits begins to run not from the actual act of cancellation, which enjoyed presumptive validity, but only from the date the Court declared the cancellation policy null and void. Where the cancellation of benefits was effected under a regulation later invalidated by the Supreme Court, the pensioner's right of action accrues only upon the promulgation of the decision striking down the regulation, and the ten-year prescriptive period under Article 1144 of the Civil Code is reckoned from that date.

Brigida V. Segundo is the widow of the late Feliciano Segundo, a veteran of the Second World War, and she has remained unremarried. She applied for pension benefits with the Philippine Veterans Board (now the Philippine Veterans Affairs Office) under Republic Act No. 65, as amended, known as the Veterans' Bill of Rights, a social legislation designed to compensate war veterans and their bereaved for injuries sustained in the line of duty. Her application was approved effective April 1947, entitling her to a monthly pension for life on condition that she remains unremarried and that no other similar benefits from the U.S. Government have been granted to her.

Brigida V. Segundo is the widow of the late Feliciano Segundo, a veteran of the Second World War, and she has remained unremarried. Soon after the death of her husband, she applied for pension benefits with the Philippine Veterans Board, then known as the Philippine Veterans Board. Her application was approved effective April 1947, and she became entitled to a monthly pension for life on condition that she remains unremarried and that no other similar benefits from the U.S. Government have been granted to her.

In November of 1951, the respondent cancelled and terminated the petitioner's monthly pension benefits because she was the recipient of a similar benefit from the U.S. Veterans Administration, which was a violation of its standing policy. It appears that on June 27, 1973, the Supreme Court, in the case of Del Mar vs. Philippine Veterans Administration, 51 SCRA 340, declared this policy of the respondent null and void. Notwithstanding the decision of the Supreme Court, the respondent still refused to restore the monthly pension of the petitioner.

On September 29, 1975, the trial court issued an order, the dispositive portion of which directed the respondent to pay petitioner her monthly life pension effective November 1951, pursuant to the provisions of Republic Act No. 65 and subsequent amendatory acts, subject to the availability of funds appropriated and/or released for the purpose, without pronouncement as to costs. The petitioner appealed, submitting three assigned errors: (I) that the lower court erred in holding that the action to compel restoration of the monthly pension effective from the date of cancellation in November 1951 had not prescribed; (II) that the lower court erred in holding that Del Mar vs. Philippine Veterans Administration is applicable to the instant case; and (III) that the lower court erred in not dismissing the petition for mandamus for lack of cause of action because no demand was made for restoration nor was there a refusal by the respondent to comply, and in view of the ruling in Board of Administration, Philippine Veterans Administration vs. Hon. Mariano V. Agcaoili, et al., G.R. No. L-38128, promulgated July 23, 1974.

• Prescription: Petitioner argued that the lower court erred in holding that the action to compel restoration of the monthly pension effective from the date of cancellation in November 1951 had not prescribed.
• Applicability of Del Mar: Petitioner argued that the lower court erred in holding that Del Mar vs. Philippine Veterans Administration is applicable to the instant case, since prescription was never raised therein.
• Lack of Cause of Action for Mandamus: Petitioner argued that the lower court erred in not dismissing the petition for mandamus for lack of cause of action because (a) no demand whatsoever was made by the petitioner for the restoration of her monthly pension nor was there a refusal by the respondent to comply therewith, and (b) in view of the ruling in Board of Administration, Philippine Veterans Administration vs. Hon. Mariano V. Agcaoili, et al., G.R. No. L-38128, promulgated July 23, 1974.

N/A — The decision does not recount the respondent's arguments in detail; the Court's discussion focuses on the petitioner's assigned errors and the Court's own reasoning in resolving them.

• Prescription: Whether the respondent's action to compel the restoration of her monthly pension effective from the date of cancellation in November 1951 had prescribed.
• Applicability of Del Mar: Whether Del Mar vs. Philippine Veterans Administration is applicable to the instant case notwithstanding that prescription was never raised therein.
• Mandamus and Prior Demand: Whether mandamus lies in the absence of a prior demand for the restoration of the monthly pension.
• Appropriations Requirement: Whether the ruling in Board of Administration, PVA vs. Agcaoili — that claims for public funds must be covered by an appropriation — applies to bar the respondent's claim.

• Prescription: No. The respondent's claim had not prescribed. The prescriptive period cannot be counted from the actual act of cancellation in November 1951, when the cancellation enjoyed presumptive validity; the ten-year period under Article 1144 of the Civil Code began to run only from June 27, 1973, when Del Mar struck down section 6 of Regulation No. 2. The respondent filed her petition on February 28, 1974, well within the ten-year period.
• Applicability of Del Mar: Yes. Del Mar is the ruling case law on the matter and applies whether to parties or non-parties. The challenge to the validity of the petitioner's rules is an act that does not admit of prescription, and prescription commenced to run again only from the date invalidity was declared.
• Mandamus and Prior Demand: No. Mandamus lies even without a prior demand. When a case involves solely legal questions, the litigant need not exhaust all administrative remedies before judicial relief is sought.
• Appropriations Requirement: No. Agcaoili does not apply. Agcaoili involved an action to compel payment of additional benefits under Republic Act No. 5753, whereas the respondent here is asking the resumption of cancelled monthly pension payments, the funding for which has been appropriated.

• Prescription: The Court reiterated its holding in Espanol vs. Chairman, Philippine Veterans Administration, No. L-44616, June 29, 1985, 137 SCRA 314, that the prescriptive period cannot be counted from the actual act of cancellation because at such time, the right of action of the party does not as yet accrue. The statute of limitations begins to run from the moment the right of action accrues. A cause of action arises when: (1) there exists a right in favor of the plaintiff under the law or contract; (2) there is a corresponding duty, by law or contract, on the part of the defendant to honor that right; and (3) there has been an act or omission by the defendant in violation of that right for which the law provides relief. The cancellation of pension benefits in November 1951 continued to enjoy a presumptive validity and hence could not be considered a violation of the right of the pensioner. The ten-year period must be reckoned from the promulgation of Del Mar on June 27, 1973, when section 6 of Regulation No. 2 was struck down; it is only then that the party's right of action can be said to acquire life. The respondent filed her petition on February 28, 1974, within the ten-year period.
• Applicability of Del Mar: The Court held that Del Mar did not consider prescription because the challenge to the validity of the petitioner's rules is an act that does not admit of prescription. Prescription, however, commenced to run again from the date invalidity was declared. To sustain the veteran's office would be to allow it to perpetuate a policy the Court had already declared null and void. Decisions of the Supreme Court applying or interpreting the laws or the Constitution form part of the legal system of the Philippines and are "laws" by their own right because they interpret what the laws say or mean. Unlike rulings of the lower courts, which bind the parties to specific cases alone, the Supreme Court's judgments are universal in their scope and application and equally mandatory in character. To defy the Court's decisions is to court contempt. Del Mar is the ruling case law on the matter and applies whether to parties or non-parties.
• Mandamus and Prior Demand: The Court reiterated that when a case involves solely legal questions, the litigant need not exhaust all administrative remedies before judicial relief is sought. Thus, the absence of a prior demand does not bar the petition for mandamus.
• Appropriations Requirement: The Court rejected the application of Agcaoili, which involved an action to compel payment of additional benefits under Republic Act No. 5753. In the case at bar, the respondent is asking the resumption of cancelled monthly pension payments, the funding for which has been appropriated. Republic Act No. 65, as amended, the Veterans' Bill of Rights, is a social legislation and must be construed most strongly in favor of its beneficiaries. The Court cited the 1973 Constitution, Article II, Section 7, and the 1987 Constitution, Article II, Section 9 and Article XVI, Section 7, which express the State's concern for war veterans and their surviving spouses and orphans.

• Prescription of actions against administrative acts — The prescriptive period for an action challenging an administrative act begins to run only when the right of action accrues, which requires the existence of a right in favor of the plaintiff, a corresponding duty on the part of the defendant, and an act or omission by the defendant in violation of that right. Where an administrative act enjoys presumptive validity, it cannot be considered a violation of the plaintiff's right, and the right of action accrues only upon the declaration of invalidity. The Court applied this doctrine to hold that the ten-year prescriptive period for the respondent's claim began to run from June 27, 1973, the date Del Mar was promulgated, not from the actual cancellation in November 1951.
• Prospective application of rulings declaring invalidity — A challenge to the validity of a rule is an act that does not admit of prescription, but prescription commences to run from the date invalidity is declared. The Court applied this principle to reckon the prescriptive period from the promulgation of Del Mar.
• Doctrine of stare decisis and the universal application of Supreme Court decisions — Decisions of the Supreme Court applying or interpreting the laws or the Constitution form part of the legal system of the Philippines and are "laws" by their own right. Unlike rulings of the lower courts, which bind the parties to specific cases alone, the Supreme Court's judgments are universal in their scope and application and equally mandatory in character. The Court applied this doctrine to hold that Del Mar applies whether to parties or non-parties.
• Exhaustion of administrative remedies — When a case involves solely legal questions, the litigant need not exhaust all administrative remedies before judicial relief is sought. The Court applied this doctrine to reject the petitioner's argument that mandamus does not lie in the absence of a prior demand.
• Social legislation construed in favor of beneficiaries — Republic Act No. 65, as amended, the Veterans' Bill of Rights, is a social legislation and must be construed most strongly in favor of its beneficiaries. The Court applied this principle in affirming the restoration of the respondent's pension benefits.

• "That the respondent's claim has prescribed lacks merit." — This passage states the Court's rejection of the petitioner's first assigned error and introduces the Court's analysis of the prescription issue.
• "In Espanol, supra, we said that the prescriptive period cannot be counted from the actual act of cancellation and that at such a time, the right of action of such a party does not as yet accrue." — This passage articulates the controlling doctrine on when the prescriptive period begins to run for actions challenging administrative acts that enjoy presumptive validity.
• "Unlike rulings of the lower courts, which bind the parties to specific cases alone, our judgments are universal in their scope and application, and equally mandatory in character. Let it be warned that to defy our decisions is to court contempt." — This passage articulates the doctrine of the universal application of Supreme Court decisions and the mandatory character of its judgments.
• "Republic Act No. 65, as amended, The Veterans' Bill Of Rights, is a social legislation, and as such, must be construed most strongly in favor of its beneficiaries." — This passage states the principle of liberal construction of social legislation in favor of its beneficiaries, which the Court applied in affirming the restoration of the respondent's pension.

• Espanol vs. Chairman, Philippine Veterans Administration, No. L-44616, June 29, 1985, 137 SCRA 314 — Controlling precedent, followed. The Court reiterated its holding in Espanol on the reckoning of the prescriptive period from the promulgation of Del Mar, the non-applicability of the exhaustion of administrative remedies rule where only legal questions are involved, and the rejection of the application of Agcaoili.
• Del Mar vs. Philippine Veterans Administration, No. L-27299, June 27, 1973, 51 SCRA 340 — Controlling precedent, followed. The Court declared section 6 of Regulation No. 2 null and void, and the Court in the instant case held that Del Mar is the ruling case law on the matter, applying whether to parties or non-parties.
• Board of Administration, Philippine Veterans Administration vs. Hon. Mariano V. Agcaoili, et al., No. L-38128, July 23, 1974, 58 SCRA 72 — Distinguished. The Court rejected its application because Agcaoili involved an action to compel payment of additional benefits under Republic Act No. 5753, whereas the respondent here sought the resumption of cancelled monthly pension payments, the funding for which had been appropriated.
• Sevarillos vs. Hermosisima, 100 Phil. 501 (1956) — Cited in support of the proposition that decisions of the Supreme Court interpreting the laws form part of the legal system of the Philippines and are "laws" by their own right.

• Article 1144, paragraph 2, Civil Code — The ten-year prescriptive period for actions upon a written contract. The Court applied this provision to determine that the respondent's action, filed on February 28, 1974, was within the ten-year period reckoned from June 27, 1973, the date Del Mar was promulgated.
• Article 8, Civil Code — Judicial decisions applying or interpreting the laws or the Constitution shall form part of the legal system of the Philippines. The Court cited this provision to support the universal application of Del Mar to parties and non-parties alike.
• Republic Act No. 65, as amended (The Veterans' Bill of Rights) — The statute granting pension benefits to war veterans and their surviving spouses. The Court construed it as a social legislation that must be interpreted most strongly in favor of its beneficiaries.
• Article II, Section 7, 1973 Constitution — The State shall establish, maintain, and ensure adequate social services in the field of education, health, housing, employment, welfare, and social security. The Court cited this provision to underscore the State's duty to provide social services.
• Article II, Section 9, 1987 Constitution — The State shall promote a just and dynamic social order that will ensure the prosperity and independence of the nation and free the people from poverty through policies that provide adequate social services. The Court cited this provision to emphasize the State's concern for social welfare.
• Article XVI, Section 7, 1987 Constitution — The State shall provide immediate and adequate care, benefits, and other forms of assistance to war veterans of military campaigns, their surviving spouses and orphans. The Court cited this provision to emphasize the State's specific duty to war veterans and their families.

Melencio-Herrera (Chairperson), Paras, and Padilla, JJ., concurred.

N/A — No dissenting opinions are noted in the provided text.