*Case: National Police Commission vs.

Judge De Guzman

*Facts: RA 6975, otherwise known as "An Act Establishing the Philippine National Police
Under a Reorganized Department of the Interior and Local Government", took effect on January
2, 1991. RA 6975 provides for a uniform retirement system for PNP members. Based on the
provision, petitioners sent notices of retirement to private respondents who are all members of
the defunct Philippine Constabulary and have reached the age of fifty-six. Private respondents
filed a complaint for declaratory relief with prayer for the issuance of an ex parte restraining
order and/or injunction before the RTC of Makati. They aver that the age of retirement set at
fifty-six by Section 39 of RA 6975 cannot be applied to them since they are also covered by Sec.
89. Respondents added that the term "INP" includes both the former members of the Philippine
Constabulary and the local police force who were earlier constituted as the Integrated National
Police (INP) by virtue of PD 765 in 1975. On the other hand, it is the belief of petitioners that the
4-year transition period provided in Section 89 applies only to the local police forces who
previously retire, compulsorily, at age sixty for those in the ranks of Police/Fire Lieutenant or
higher, while the retirement age for the PC had already been set at fifty-six under the AFP law.
Respondent judge De Guzman issued a restraining order followed by a writ of injunction. He
declared that the term "INP" in Section 89 of the PNP Law includes all members of the present
Philippine National police, irrespective of the original status of the present members of the
Philippine National police before its creation and establishment, and that Section 39 thereof shall
become operative after the lapse of the four-year transition period. Thus, the preliminary
injunction issued is made permanent. Moreover, he observed, among others, that it may have
been the intention of Congress to refer to the local police forces as the "INP" but the PNP Law
failed to define who or what constituted the INP. The natural recourse of the court is to trace the
source of the "INP" as courts are permitted to look to prior laws on the same subject and to
investigate the antecedents involved.

*Issue: Whether or not Section 89 of the PNP Law includes all members of the present
Philippine National police, irrespective of the original status of its present members and that
Section 39 of RA 6975 shall become applicable to petitioners only after the lapse of the four-year
transition period.

*Ruling: It appears that the use of the term INP is not synonymous with the PC. Had it been
otherwise, the statute could have just made a uniform reference to the members of the whole
Philippine National police (PNP) for retirement purposes and not just the INP. 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. Contrary to the pronouncement of respondent judge that “the law failed
to define who constitutes the INP”, Sec. 90 of RA 6975 has in fact defined the same. It is not
altogether correct to state, therefore, that the legislature failed to define who the members of the
INP are. In this regard, it is of no moment that the legislature failed to categorically restrict the
application of the transition period in Sec. 89 specifically in favor of the local police forces for it
would be a mere superfluity as the PC component of the INP was already retirable at age fifty-
six. Having defined the meaning of INP, the trial court need not have belabored on the supposed
dubious meaning of the term. Nonetheless, if confronted with such a situation, courts are not
without recourse in determining the construction of the statute with doubtful meaning for they
may avail themselves of the actual proceedings of the legislative body. 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. Courts should not give a literal interpretation to the letter of the
law if it runs counter to the legislative intent. (1) It must be based upon substantial distinctions;
(2) It must be germane to the purpose of the law; (3) It must not be limited to existing conditions
only; (4) It must apply equally to all members of the same class.