By Benjamin Cuaresma
MANILA — The Supreme Court (SC) has declared invalid a Government Service Insurance System (GSIS) rule that barred secondary beneficiaries from receiving survivorship benefits when a deceased member had rendered at least three but less than 15 years of government service.
In a decision penned by Associate Justice Henri Jean Paul B. Inting, the SC Third Division ruled that Section 24.2.2 of the Revised Implementing Rules and Regulations (IRR) of Republic Act No. 8291, otherwise known as the GSIS Act of 1997, exceeded the agency’s rule-making authority and was therefore void.
The Court held that the provision unlawfully added requirements not found in the law, effectively denying benefits to qualified secondary beneficiaries.
The case stemmed from the claim of Petronilo B. Laroco, who sought survivorship benefits following the death of his daughter, Cristie C. Laroco, a public school teacher who had served in government for 13 years and paid GSIS contributions for 12 years.
Cristie died unmarried and without children, leaving no primary beneficiaries such as a spouse or offspring. Laroco, as her father, applied for survivorship benefits as a secondary beneficiary.
The GSIS denied the claim, citing its IRR provision that limited survivorship benefits for secondary beneficiaries to cases where the deceased member had completed at least 15 years of government service.
The Court of Appeals later affirmed the GSIS ruling, prompting Laroco to elevate the case to the Supreme Court.
In reversing the lower court’s decision, the SC emphasized that the GSIS Act clearly grants survivorship benefits to secondary beneficiaries when there are no primary beneficiaries, the claimant satisfies the dependency requirements, the member dies while in government service, and the member has rendered at least three years of service.
According to the Court, the disputed GSIS rule improperly imposed an additional requirement by restricting benefits only to cases involving members with at least 15 years of service.
“The GSIS cannot amend or modify the law through administrative regulations,” the Court stressed, noting that only Congress has the authority to alter statutory provisions.
The High Court acknowledged GSIS concerns about perceived disparities in benefit entitlements between members with shorter and longer years of service. However, it ruled that any policy changes must be addressed through legislative amendments rather than administrative issuances.
The Court further underscored that social security laws must be liberally construed in favor of workers and their beneficiaries, as these statutes are intended to protect against financial hardships arising from disability, death, and other contingencies.
“Social security statutes are designed to promote social justice and safeguard workers and their families from loss of income and financial burden,” the decision stated.
As a result, the SC ordered the case remanded to the GSIS Committee on Claims for the computation and release of the survivorship benefits due to Laroco.
The ruling is expected to benefit similarly situated secondary beneficiaries who were previously denied claims under the now-invalid GSIS regulation.
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