DBM v Manila's Finest

G.R. No. 169466, May 9, 2007

Facts of the Case

1975- PD 765 was issued constituting the Integrated National Police (INP) to be composed of the
Philippine Constabulary (PC) as the nucleus and the integrated police forces as components

1977- PD 1184 complemented PD 765, which was issued to professionalize the INP and promote career
development therein

1990- RA 6975 (An Act Establishing the Philippine National Police Under a Reorganized Department of
the Interior and Local Government, PNP Law was enacted

Under Sec. 23, the PNP would initially consist of the members of the INP, created under PD 675, as well
as the officers and enlisted personnel of the PC

1998- RA 6975 was amended by RA 8551 (Philippine National Police Reform and Reorganization Act of
1998)

Amendatory law that reengineered the retirement scheme in the police organization

It enabled the PNP to have higher retirement benefits that the INP and Philippine Constabulary (PC)

2002- Manila's Finest Retirees Association, Inc. (MFRAI) (consisted of INP retirees) filed a petition for
declaratory relief against DBM, PNP, NAPOLCOM, CSC, and GSIS

MFRAI's petition stated that they are absorbed and equally considered as PNP-retirees and thus, entitled
to enjoy the same or identical retirement benefits bestowed to PP-retirees by virtue of the PNP Law (RA
6975), as amended by RA 8551

GSIS moved to dismiss on the grounds of lack of jurisdiction and cause of action

CSC, DBM, NAPOLCOM, and PNP replied that the petitioners are not entitled to have equal retirement
benefits as PNP-retirees because the former have already retired prior to the enactment of RA 6975

2003- RTC ruled that RA 6975 did not abolish the INP but merely provided for its absorption of its police
functions by the PP

April 2003- RTC granted GSIS's motion to dismiss

2005- CA affirmed RT's decision that the INP should have equal or identical retirement benefits as the
PNP under RA 6975

Petitioners filed a petition w/ the SC assailing that the CA committed a serious error in law in affirming
the decision of the RTC notwithstanding that it is contrary to law and established jurisprudence

Issue

W/N the INP should have equal or identical retirement benefits as the PNP under RA 6975, as

amended by RA 8551
III. Ruling

yes

The court stated that during Martial Law, the PC-INP had a military character, being then a major service
of the AFP, but was subsequently removed under the control and supervision from the military, after the
Marcos regime, for the establishment of one police force which should be national in scope and, most
importantly, purely civilian in character The PNP was created precisely to erase the stigma spawned by
militarization of the police force under the PC-INP structure.

The court mentioned Sec. 2 of RA 6975 which stated:

Section 2. Declaration of policy - It is hereby declared to be the policy of the State to promote peace and
order, ensure public safety and further strengthen local government capability aimed towards effective
delivery of the basic services to the citizenry through the establishment of highly efficient and
competent police force that is national in scope and civilian in character.

The police force shall be organized, trained and equipped primarily for the performance of police
functions. Its national scope and civilian character shall be paramount. No element of the police force
shall be military nor shall any position thereof be occupied by active members of the AFP.

Sec. 23 of RA 6975 also states that the PNP is initially consisted of the members of the police forces who
were integrated into the INP by virtue of PD765