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NATIONAL POLICE COMMISSION v. JUDGE SALVADOR DE GUZMAN

FACTS:

The case involves the implementation of the compulsory retirement of Philippine National Police (PNP) officers as mandated by Section 39 of Republic Act (RA) No. 6975. The petitioners sent retirement notices to the private respondents, who are members of the defunct Philippine Constabulary (PC) and have reached the age of 56, as required by the law. The private respondents filed a complaint seeking a declaratory relief and restraining order, arguing that they are covered by Section 89 of RA 6975, which provides for a transition period of four years for the compulsory retirement of members of the Integrated National Police (INP). The private respondents contend that the term "INP" includes both former members of the PC and the local police force. The trial court issued a restraining order and injunction in favor of the private respondents. The court then declared that the term "INP" in Section 89 includes all members of the present Philippine National Police, irrespective of their original status. The petitioners filed a petition seeking the reversal of the decision.

ISSUES:

  1. Does the law, RA 6975, distinguish INP from the PC?

  2. Does the term "INP" in Section 89 of RA 6975 include the members of the PC?

  3. Whether or not Section 89 of Republic Act No. 6975 (RA 6975) applies only to the local police force and not to the members of the Philippine Constabulary (PC).

  4. Whether or not the classification of the retirement age between the local police force and the PC is valid.

RULING:

  1. Yes, the law, RA 6975, distinguishes INP from the PC. The provisions of Sec. 23 and Sec. 85 of RA 6975 show that the term "INP" is not synonymous with the PC. The law itself distinguishes INP from the PC, and it cannot be construed that "INP" as used in Sec. 89 includes the members of the PC.

  2. No, the term "INP" in Section 89 of RA 6975 does not include the members of the PC. The law defines INP in Section 90, which states that the present PC-INP will cease to exist and a new police force will be established. Hence, the term "INP" as used in Sec. 89 does not cover the members of the PC.

  3. Yes, Section 89 of RA 6975 applies only to the local police force. The Court based its interpretation on the deliberations of the Bicameral Conference Committee that preceded the enactment of RA 6975. The Court did not give any undue preferential treatment to the local police force but merely gave life to the real intent of the legislators.

  4. The classification of the retirement age between the local police force and the PC is valid. The classification is based on substantial distinctions as the PC and the local police force were governed by different laws before the effectivity of RA 6975. The distinction is relevant for the purpose of the statute, which is to enable the local police force to plan for their retirement earlier than usual because of the new law. The classification is reasonable as it satisfies the requirements of reasonableness, including substantial distinction, germaneness to the purpose of the law, generality, and equality among members of the same class.

PRINCIPLES:

  • Courts should not give a literal interpretation to the letter of the law if it runs counter to the legislative intent.

  • In case of doubt as to what a provision of a statute means, the meaning put to the provision during the legislative deliberations may be adopted.

  • When the law itself distinguishes between two terms, it cannot be construed that one term includes the other.

  • Classification for purposes of legislation must be based on substantial distinctions.

  • Classification must be germane to the purpose of the law.

  • Classification should not be limited to existing conditions only.

  • Classification must apply equally to all members of the same class.

  • The Court's interpretation of a statute should give life to the real intent of the legislators based on the deliberations preceding its enactment.