"Inflexible rule in Philippine jurisdiction: SOCIAL LEGISLATION must be LIBERALLY

construed in favor of the BENEFICIARIES."

LAWS ON AGRARIAN REFORM

- liberally construed in favor of intended beneficiaries
ratio: ensure realization of CONSTITUTIONAL MANDATE on the promotion of social
justice in promoting the well-being and econimic security of the people

SOCIAL JUSTICE definition: the adoption of the Gov't "of measures calculated to
insure economic stability of all component elements of society, through the
maintenance of a proper economic and social equilibrium in the unter-relations of
the members of the community"

SC is guided by more than a literal meaning of the law; broad considerations

bearing upon the proper interpretation pf tenancy and labor lebislatiins are the
ultimate resolution if doubts in favor of the tenant/worker
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GSIS v. De Leon (G.R. No. 186560, 2010 Nov 17)
SC affirmed grant of reinstatement of retirement benefits of DE LEON (Chief State
Prosecutory under DOJ) under RA 910 (act providing for retirement of justicies;
Chief STate Prosecutor - same rank as judges)

GSIS - granted his retirement and provided his benefits for 9 YEARS
- subsequently cancelled pension due to refusal of DBM Sec. BONCODIN to
release funds (not covered under RA 910)

DE LEON sought to secure benefits under any other applicable law GSIS treated it as
doule retirement (can't sanction)
- petition for mandamus (CA & SC granted)

Proper application of retirement laws with are in the lcass of social legislation

Retirement laws - liberally construed in favor of the retiree

- objective is to provide for retiree's sustenance (and, hopefully,
even comfornt) when he no longer has the capability to earn a livelihood

LIBERAL APPROACH - aims to achieve the humanitarian purposes of the law in order
that efficiency, security, and well-being of government employees may be enhanced

SC found that DE LEON qualified under PD 1146 (latest applicable law

==================================
"Avowed policy of the State: construe social legislation liberally in favor of the
beneficiaries and RESOLVE ALL DOUBTS in their favor"
Purpose of policy:
- give social legislation an interpretation that would achieve its
HUMANITARIAN PURPOSE
- give full force and effect to the CLEAR INTENT: promote the economic and
social stability of its beneficiaries

Principle is upheld in labor laws, retirement laws, and agrarian laws.

_______________________________________
Obra v. SSS (G.R. No. 147745, 2003 April 09)

Claim for death benefits of a widow, MARIA OBRA.

Husband was a dump truck driver who died (1988 June 27) from a heart attack while
driving inside the work compound.
OBRA filed claim under the SSS Law without knowledge of the Employees Compensation
Commission benefits granted under PD 626 (if employee died while working for the
company), until 10 years later.
OBRA filed a claim (1999 April 23) for funeral benefits, but SSS and ECC denied
her claim on the ground of PRESCRIPTION (3 years from the time the cause of action
accrued --- Art. 201 of PD 626 and Sec. 6, Rule VII of the 1987 Amended Rules on
Employees' Compensation), among others.

SC granted the claim as an EXCEPTION to the 3-year prescription, as found in Board

Resolution 93-08-0068 and ECC Rules of Procedure for the Filing and Disposition of
Employees' Compensation Claims.
BOARD RESOLUTION
any claim filed within the System for any contingency that may be held
compensable under the Employee's Compensation Program (ECP)shall be considered as
the EC claim itself.
ECC Rules of Procedure
claims filed beyond the 3-year prescriptive period may still be given due
course, provided that a claim for Medicare, sickness, burial, disability of death
was filed within three years from the occurrence of the contingency.

SC: OBRA's claim for death benefits under the SSS law should be considered as the
EC claim itself (because it is of the same nature as the claim before the ECC, and
SSS is the same agency with which EC claims are filed)

______________________________________________
Castillo v. Tolentino (G.R. No. 181525, 2009 March 04)

(Although the Court recognized the liberal policy in favor of social legislation,
it emphasized that) social justice is not intended to countenance wrongdoing simply
because it is committed by the underprivileged.

SC explained that RA 3844 and RA 6389, being social legislations were designed to
promote economic and social stability and must be interpreted liberally to give
full force and effect to their clear intent, not only in favor of the TENANT-
FARMERS but also of LANDOWNERS.

Issue arose from the construction of a concrete water reservoir within TOLENTINO's
land by his agricultural lessee CASTILLO, without his consent and over his
objection.
Construction was improper, being done without complying with Section 32 of RA 3844
- requires notice to and consent of agricultural lessor

CASTILLO invoked social justice

SC recognized liberality of agrarian laws to its beneficiaries, that agrarian laws

were enacted to help small farmers uplift their economic status... but while
agrarian reform laws significantly favor tenans, farmworkers ando ther
beneficiaries, it cannot allow practices that resulti nt he oppression of ordinary
landowners as to deprive them of their land, especially when these practices are
committed by the very beneficiaries of these laws.
Social justice was not meant to perpetrate an injustice against the landowner.
RA 3844 did not operate to take away every landowner's rights to his land and did
not authorize the agricultural lessee to act in an abusive mannerin derogation of
the landowner's rights

___________________________________
Francisco Estolas v. Adolfo Mabalot (G.R. No. 133706, 2002 May 07)
SC emphasized that liberal interpretat�on of agrarian laws are for purpose of
giving full force and effect to the CLEAR INTENT of such laws: "to achieve a
dignified existence for the small farmers" and to make them "more independent,
self-reliant and responsible citizens, and a source of genuine strength in our
democratic society"

========
Other examples:
RA 1199 (Agricultural Tenancy Act) - Alfanta v. Noel
Agricultural Land Reform Code
PD 27 - anyone who wishes to contest the rights of the (beneficiary) has the burden
of proving that he doesn't deserve the benefit

ELECTION LAWS
employ liberal interpretation to EXPRESS THE WILL OF THE PEOPLE

Pe�a v. House of Representatives ET (G.R. No 123037, 1997 March 21)

Election allegedly tainted with massive fraud, vote-buying, intimidation, and other
irregularities