DOCTRINE OF STARE DECISIS

Philippine National Bank v. Giovanni Palma, et al.

G.R. No. 157279, August 9, 2005

DOCTRINE:

The doctrine "Stare decisis et non quieta movere (Stand by the decisions and disturb not what
is settled)" is firmly entrenched in our jurisprudence. Once the Court has laid down a principle of
law as applicable to a certain state of facts, it would adhere to that principle and apply it to all
future cases in which the facts are substantially the same as in the earlier controversy

FACTS:

R.A. 6758 otherwise known as “An Act Prescribing a Revised Compensation and Position
Classification System in the Government and For Other Purposes took effect on 1 July 1989;

Section 12 thereof provides for the consolidation of allowances and additional compensation
into standardized salary rates, but certain additional compensation were exempted from
consolidation;

The Department of Budget and Management (DBM) issued Corporate Compensation Circular
No. 10 (DBM-CCC No. 10) to implement R.A. 6758. Section 5.5 of DBM-CCC No. 10
enumerated the other allowances/fringe benefits which are not likewise integrated into the basic
salary rates prescribed under R.A. 6758, but were allowed to be continued only for incumbents
as of 30 June 1989;

On 12 August 1998, the Supreme Court, in the case of De Jesus, et. al. vs. Commission on
Audit (COA) held that DBM-CCC No. 10 was ineffective due to its non-publication in the Official
Gazette or in a newspaper of general circulation;

In view of the declaration made by the Supreme Court in the above-mentioned case, a petition
for mandamus was filed by Respondents Palma, et. al. and alleged, among other things, that
they are employees hired by PNB on various dates after 30 June 1989; that from the dates of
their respective appointments until 1 January 1997 they were unjustly deprived and denied of
the following allowances being enjoyed by other employees of the PNB;
PNB, on the other hand, invokes the doctrine of stare decisis by arguing that the proper
interpretation of Section 12 of RA 6758 was already settled with finality in Philippine Ports
Authority v. COA, Manila International Airport Authority v. COA, Philippine International Trading
Corporation v. COA, and Social Security System v. COA.

ISSUE:

Are respondents Palma, et. al. entitled to the fringe benefits?

RULING:

NO. The doctrine "Stare decisis et non quieta movere (Stand by the decisions and disturb not
what is settled)" is firmly entrenched in our jurisprudence. Once the Court has laid down a
principle of law as applicable to a certain state of facts, it would adhere to that principle and
apply it to all future cases in which the facts are substantially the same as in the earlier
controversy.
In this case, the precise interpretation and application of the assailed provisions of RA 6758,
namely those in Section 12, have long been established in Philippine Ports Authority v. COA.
The essential pronouncements in that case have further been fortified by Manila International
Airport Authority v. COA, Philippine International Trading Corporation v. COA, and Social
Security System v. COA. The Court has consistently held in those cases that allowances or
fringe benefits, whether or not integrated into the standardized salaries prescribed by RA 6758,
should continue to be enjoyed by employees who (1) were incumbents and (2) were receiving
those benefits as of July 1, 1989.
In consonance with stare decisis, there should be no more misgivings about the proper
application of Section 12. Here, the payment of benefits to employees hired after July 1, 1989,
was properly withheld, because the law clearly mandated that those benefits should be reserved
only to incumbents who were already enjoying them before its enactment. Withholding them
from the others ensured that the compensation of the incumbents would not be diminished in
the course of the latter’s continued employment with the government agency.