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    Case Digest - Maritime Industry Authority v. COA

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    Aj Dalida
    The Supreme Court ruled that the allowances granted by the Maritime Industry Authority to its officers and employees did not have a legal basis. Section 12 of the Compensation and Position Classification Act of 1989 deemed all allowances to be integrated into standardized salary rates, with some exceptions. While the MIA argued certain allowances were not integrated, the Court found the allowances disallowed were already accounted for in salaries. Rules and regulations must be consistent with statutes, and statutory provisions take precedence over conflicting rules.

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    Case Digest - Maritime Industry Authority v. COA

    Uploaded by

    Aj Dalida
    655 views1 page
    The Supreme Court ruled that the allowances granted by the Maritime Industry Authority to its officers and employees did not have a legal basis. Section 12 of the Compensation and Position Classification Act of 1989 deemed all allowances to be integrated into standardized salary rates, with some exceptions. While the MIA argued certain allowances were not integrated, the Court found the allowances disallowed were already accounted for in salaries. Rules and regulations must be consistent with statutes, and statutory provisions take precedence over conflicting rules.

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    The Supreme Court ruled that the allowances granted by the Maritime Industry Authority to its officers and employees did not have a legal basis. Section 12 of the Compensation and Position Classification Act of 1989 deemed all allowances to be integrated into standardized salary rates, with some exceptions. While the MIA argued certain allowances were not integrated, the Court found the allowances disallowed were already accounted for in salaries. Rules and regulations must be consistent with statutes, and statutory provisions take precedence over conflicting rules.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    655 views1 page

    Case Digest - Maritime Industry Authority v. COA

    Uploaded by

    Aj Dalida
    The Supreme Court ruled that the allowances granted by the Maritime Industry Authority to its officers and employees did not have a legal basis. Section 12 of the Compensation and Position Classification Act of 1989 deemed all allowances to be integrated into standardized salary rates, with some exceptions. While the MIA argued certain allowances were not integrated, the Court found the allowances disallowed were already accounted for in salaries. Rules and regulations must be consistent with statutes, and statutory provisions take precedence over conflicting rules.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    MARITIME INDUSTRY AUTHORITY HELD:

    VS. COMMISSION ON AUDIT


    The Department of Budget and Management’s National Compensation
    Circular No. 59 issued on September 30, 1989 enumerates the
    FACTS: allowances/additional compensation of government employees that are
    deemed integrated into the basic salary. It does not identify an allowance that
    o Petitioner is an attached agency of the Department of Transportation should not be deemed as integrated in the basic salary of government
    employees.
    and Communication created under PD No. 474
    o R.A. No. 6758, otherwise known as the Compensation and Position It is a cardinal rule in statutory construction that statutory provisions control
    Classification Act of 1989, is a law which standardizes the salary the rules and regulations which may be issued pursuant thereto. Such rules
    rates of government officials and employees. Section 12 of said law and regulations must be consistent with and must not defeat the purpose of
    provides that all allowances (except for representation and the statute. The validity of R.A. No. 6758 should not be made to depend on
    transportation; clothing and laundry; subsistence allowance of the validity of its implementing rules.
    marine officers and crew on board gov’t vessels and hospital
    RULING:
    personnel; hazard pay; allowances of foreign service personnel
    stationed abroad; and other additional compensation that may be The disallowed allowances granted by MIA to its officers and employees are
    determined by the DBM) shall be deemed included in the already integrated in the standardized salary rates and therefore have no
    standardized salary rates. legal basis.
    o MIA discontinued the grant of several allowances to its officials and
    employees due to the issuance of National Compensation Circular
    IMPORTANT NOTES:
    Nos. 56 and 59 by the DBM.
    o The Administrator of MIA recommended to then President Estrada Cardinal is the rule in statutory construction "that the particular words,
    the approval/restoration of allowances to the officers and employees clauses and phrases should not be studied as detached and isolated
    of MIA through a memorandum. Said memorandum was allegedly expressions, but the whole and every part of the statute must be considered
    stamped and signed by the President, so MIA started granting in fixing the meaning of any of its parts and in order to produce a harmonious
    allowances to its officers and employees again. whole. A statute must be so construed as to harmonize and give effect to all
    o Petitioner argues that the allowances granted to its officers and its provisions whenever possible." And the rule - that statute must be
    construed as a whole - requires that apparently conflicting provisions should
    employees are not integrated in the standardized salary.
    be reconciled and harmonized, if at all possible. It is likewise a basic precept
    o Petitioner understands the last clause of the first sentence of Sec. 12 in statutory construction that the intent of the legislature is the controlling
    of RA No. 6758 as requiring a subsequent issuance by the DBM so factor in the interpretation of the subject statute. With these rules and the
    that other allowances not specifically enumerated in the provision will foregoing distinction elaborated upon, it is evident that the two seemingly
    be excluded. irreconcilable propositions are susceptible to perfect harmony.
    o On the other hand, respondent interprets Section 12 differently
    saying that the issuance of a circular by the DBM is necessary only
    for the grant of allowance other than those enumerated under Sec.
    12 of RA No. 6758.

    ISSUE:
    Whether or not the allowances or incentives granted to the officers
    and employees of Maritime Industry Authority have legal basis. (NO)

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