“lower courts from the CA down to the lowest level must take judicial
notice of decisions of the SC as they are duty bound to know the rulings of the
high tribunal and to apply them in the adjudication of cases, they being part
of the legal system.”
Facts:
Brigida Segundo is the widow
of a veteran of the 2nd World War, the late Feliciano Segundo who
applied for a pension benefit from the Phil. Veterans Affairs. Her application
was approved in April 1947 and was entitled in receiving a monthly pension for
life on the condition that she will remain unmarried and no similar benefits
from the US Government has been granted to her. In November 1951, the respondent cancelled and
terminated the monthly pension benefits because she became a recipient of a similar
benefit from the US Veterans Administration which is in violation of the Phil
Veterans Affairs standing policy. However in June 1973, the Supreme Court declared the other policy Segundo was
receiving as null and void in the case of Del
Mar vs Phil. Veterans Administration. Despite this ruling by the SC,
Philippine Veterans Affairs refused to restore the monthly pension of Segundo.
The trial court, in a decision promulgated in March 1975, ordered the Phil.
Veterans to pay Segundo her monthly life pension effective November 1951.
Phil. Veterans Affair now
assailed the decision of the court contending that it erred in deciding that
the right of Segundo to compel them to restore her pension had not prescribed;
that the ruling in Del Mar vs Phil. Veterans Administration is not applicable
in the case and that the court should have dismissed the petition for mandamus
for lack of cause of action for her failure to demand the restoration of her
pension and there was no refusal on their part.
Issue: Whether or not the decision of the SC in the Del Mar Vs Phil
Veterans Administration is controlling in the case at bar?
Ruling:
The Supreme Court ruled that
the contention of the petitioner that the case of Del Mar vs Phil. Veterans
Administration is not applicable on this case is untenable. It is reiterated
that decisions of the Supreme Court in applying or interpreting the laws or the
Constitution form part of the legal system of the Philippines and in effect forms part
of the law by their own right because they interpret what the law say or mean. Unlike
rulings of the lower courts, which bind the parties to specific cases alone, the
SC judgments are universal in their scope and application, and equally
mandatory in character.
The court raised the fact that the
10-year period prescription upon which Segundo may raise an action to compel
the Phil. Veterans to restore her pension is reckoned from the time of the
promulgation of the decision in Del Mar case which was made in June 1973.
Segundo filed her petition in February 1974 thus it is within the 10-year
period and her action has not prescribed. Prior to the promulgation of said
judgment, the cancellation of the pension benefits of Segundo in 1951 enjoys
the presumption of validity and the right of the petitioner was not violated
during this period. Her cause of action only accrued during the promulgation of
the Del Mar case in 1973 and she filed her petition in 1974 which is well
within the prescription period. The court cannot sustain the contention of
Phil. Veterans for to do so will defy their own ruling that forms part of the
legal system.
Lastly, the SC held that it
can take cognizance on the petition of the pensioner even in the absence of any
prior demand for when a case involves solely legal questions, the litigant need
not exhaust administrative remedies before judicial relief is sought.
Note:
The statute of limitations begins
to run from the moment the right of action accrues. There is a right of action
when there exist a cause of action. A cause of action, in turn, arises; (1)
when 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.
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