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    Irene Cruz v. COA

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    Hazel P.
    The Sugar Regulatory Administration (SRA) had historically granted social amelioration benefits (SAB) to all employees from corporate funds. In 1989, a law took effect limiting additional compensation to those receiving it as of July 1, 1989. In 1994, an audit questioned SAB for all SRA employees. The Commission on Audit (COA) allowed SAB only for employees hired before October 31, 1989. The Court ruled this classification based solely on hire date was invalid, as employees in the same roles faced equal work regardless of hire date. Any distinction must be based on substantial factors like rank or difficulty, not arbitrary dates. The petition was granted and COA decision overturned.

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    Irene Cruz v. COA

    Uploaded by

    Hazel P.
    81 views2 pages
    The Sugar Regulatory Administration (SRA) had historically granted social amelioration benefits (SAB) to all employees from corporate funds. In 1989, a law took effect limiting additional compensation to those receiving it as of July 1, 1989. In 1994, an audit questioned SAB for all SRA employees. The Commission on Audit (COA) allowed SAB only for employees hired before October 31, 1989. The Court ruled this classification based solely on hire date was invalid, as employees in the same roles faced equal work regardless of hire date. Any distinction must be based on substantial factors like rank or difficulty, not arbitrary dates. The petition was granted and COA decision overturned.

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    Constitutional Law II under Equal Protection

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    The Sugar Regulatory Administration (SRA) had historically granted social amelioration benefits (SAB) to all employees from corporate funds. In 1989, a law took effect limiting additional compensation to those receiving it as of July 1, 1989. In 1994, an audit questioned SAB for all SRA employees. The Commission on Audit (COA) allowed SAB only for employees hired before October 31, 1989. The Court ruled this classification based solely on hire date was invalid, as employees in the same roles faced equal work regardless of hire date. Any distinction must be based on substantial factors like rank or difficulty, not arbitrary dates. The petition was granted and COA decision overturned.

    Copyright:

    © All Rights Reserved
    81 views2 pages

    Irene Cruz v. COA

    Uploaded by

    Hazel P.
    The Sugar Regulatory Administration (SRA) had historically granted social amelioration benefits (SAB) to all employees from corporate funds. In 1989, a law took effect limiting additional compensation to those receiving it as of July 1, 1989. In 1994, an audit questioned SAB for all SRA employees. The Commission on Audit (COA) allowed SAB only for employees hired before October 31, 1989. The Court ruled this classification based solely on hire date was invalid, as employees in the same roles faced equal work regardless of hire date. Any distinction must be based on substantial factors like rank or difficulty, not arbitrary dates. The petition was granted and COA decision overturned.

    Copyright:

    © All Rights Reserved
    of 2

    Irene Cruz v.

    Commission on Audit (COA) DOCTRINE: The date of hiring of an employee cannot be considered a
    Oct. 23, 2001 | Pardo | Equal Protection substantial distinction. The employees, based on the title or position, were exposed
    to the same type of work, regardless of the date they were hired. Any distinction
    among employees must be based on substantial distinctions, that is, level or rank,
    PETITIONER: Irene Cruz, et al. in their own behalf and in representation of their degree of difficulty and amount of work.
    co-employees, numbering 330 in the Sugar Regulatory Administration
    RESPONDENTS: Commission on Audit (COA) FACTS:
    1. This case is an appeal of the decision of the COA, denying the grant of
    SUMMARY: social amelioration benefits to employees of the Sugar Regulatory
    The Sugar Regulatory Administration (SRA), a gov’t owned corporation, adopted Administration (SRA) hired after Oct. 31, 1989.
    resolutions since 1963 granting the payment of social amelioration benefits (SAB) 2. The SRA, a gov’t owned corporation, adopted resolutions since 1963
    to all its employees sourced from corporate funds. In 1989, RA No. 6758 took granting the payment of social amelioration benefits (SAB) to all its
    effect. In 1994, Ms Villarosa, the Resident Auditor of the Commission on Audit employees sourced from corporate funds.
    in the SRA, upon examining the accounts of the SRA and pursuant to the said Act, 3. RA No. 6758 took effect in July 1989.
    questioned the legality of the payment of SAB to all SRA employees. The DBM 4. In May 1994, Ms. Villarosa, the Resident Auditor of the Commission on
    also ruled that the SAB had no legal basis and was violative of RA No. 6758. Audit in the SRA, examined the accounts of SRA. Pursuant to Sec. 12 of
    Accordingly, COA suspended the SAB. The affected employees appealed to the RA No. 6758, which provides that, “such other additional compensation,
    Office of the President for the continuation of the grant of SAB. The Office of the in cash or kind, being received by incumbents only as of July 1, 1989, not
    President, thru its Executive Secretary, issued a 1st indorsement granting post facto integrated into the standardized rates shall continue to be authorized,”
    approval or ratification of the SAB. The COA then allowed payment of the SAB Ms. Villarosa questioned the legality of the payment of the SAB to all SRA
    but only to those SRA employees hired before Oct. 31, 1989. Other employees employees.
    remained not entitled to the said benefits. The issue in this case is W/N the 5. The Dept. of Budget & Management (DBM) also ruled that the grant of
    classification of SRA employees based on the date of hiring (i.e. those hired SAB had no legal basis and was in violation of RA No. 6758.
    before and those after Oct. 31, 1989) is a valid classification. The Court ruled 6. Accordingly, the COA suspended the payment of SAB to all SRA
    in the negative. It held that the classification made by the COA as to who were employees. The affected employees then appealed to the Office of the Pres.
    entitled to the SAB and who were not based merely on the date of hiring, i.e., for the continuation of the grant of SAB.
    those hired before and those after Oct. 31, 1989, has no legal basis. The date of 7. The COA claimed that upon effectivity of RA No. 6758, the SAB was no
    hiring of an employee cannot be considered a substantial distinction. Any longer allowed unless there was prior authority from the DBM or Office
    distinction among employees must be based on substantial distinctions, that of the Pres. or a legislative issuance.
    is, level or rank, degree of difficulty and amount of work. The employees, 8. The Office of the Pres., thru Exec Secretary Ruben Torres, issued a 1 st
    based on the title or position, were exposed to the same type of work, regardless indorsement, granting post facto approval or ratification of the SAB to
    of the date they were hired. The petition is therefore granted and the COA SRA employees.
    Decision is set aside.
    9. The COA then allowed payment of the SAB but only to those SRA
    employees hired before Oct. 31, 1989. Other employees remained not
    entitled to the said benefits.

    ISSUES:
    1. W/N the classification of SRA employees based on the date of hiring
    (i.e. those hired before and those after Oct. 31, 1989) is a valid
    classification. [NO]

    RATIO:
    1. The Court held that the classification made by the COA as to who were
    entitled to the SAB and who were not based merely on the date of hiring,
    i.e., those hired before and those after Oct. 31, 1989, has no legal basis.
    2. The date of hiring of an employee cannot be considered a substantial
    distinction. The employees, based on the title or position, were exposed
    to the same type of work, regardless of the date they were hired. The date
    of hiring is not among those factors to be taken into consideration in the
    fixing of compensation or granting of benefits.
    3. Any distinction among employees must be based on substantial
    distinctions, that is, level or rank, degree of difficulty and amount of
    work. To discriminate based solely on the date if hiring is to run against
    the progressive and social policy of the law.
    4. ‘When the law does not distinguish, the courts should not distinguish’ also
    applies in this case.

    DISPOSITION:
    The Court GRANTS the petition and sets aside the COA Decision.

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