The Supreme Court has struck down a Government Service Insurance System rule that barred secondary beneficiaries from claiming survivorship benefits when the deceased government worker had served for less than 15 years.
In a decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division ruled that Section 24.2.2 of the Revised Implementing Rules and Regulations of Republic Act No. 8291, or the GSIS Act of 1997, went beyond the limits of GSIS’ rule-making authority.
The case stemmed from the petition of Petronilo B. Laroco, whose claim for survivorship benefits was denied after the death of his daughter, Cristie C. Laroco, a public school teacher at Camp Crame Elementary School.
Cristie died single and without children after rendering 13 years of government service and paying GSIS premiums for 12 years.
Petronilo, as her sole legal heir, applied for survivorship benefits. However, the GSIS Committee on Claims rejected his application, citing the rule that allowed secondary beneficiaries to claim only if the deceased member had completed at least 15 years of service.
GSIS argued that because Cristie did not meet the 15-year requirement, only primary beneficiaries, such as a legal spouse or dependent children, could receive the benefits.
Laroco appealed to the GSIS Board of Trustees and later to the Court of Appeals, but both upheld the denial. He then brought the case to the Supreme Court.
The SC ruled that the GSIS regulation conflicted with Section 21(c) of the GSIS Act by imposing an additional requirement not found in the law.
The Court said GSIS could not use its implementing rules to restrict a benefit granted by statute, even if the agency intended to address a perceived imbalance in pension distribution.
It also emphasized that social security laws must be interpreted liberally in favor of government workers and their beneficiaries.
Because GSIS membership is mandatory, the Court said accrued benefits are protected property under the Due Process Clause and serve as compensation meant to protect families from financial loss after a member’s death.
The SC set aside the rulings of the Court of Appeals and the GSIS Board of Trustees.
It remanded the case to the GSIS Committee on Claims and ordered the agency to compute and release the survivorship benefits due to Laroco.