"A law cannot be amended by a mere regulation, and the administrative agency issuing the regulation may not enlarge, alter, or restrict the provisions of the law it administers." -SC
"Death may be the end of one's life. But from the perspective of those left behind, there are things that survive a person's demise. For the romantics, it is the memories and feelings that linger long after the passing of a loved one. For the pragmatics and businesspersons alike, the financial aspects of funeral and burial are matters that persist even after one is laid to rest." -SC
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The sole issue for resolution, a purely legal question, is whether interment services are covered under RA 7432, as amended by RA 9257 and RA 9994, and thus, subject to a 20% discount on funeral and burial services for the death of senior citizens.
Petitioners argue that the terms of the assailed statutes are not doubtful as to require judicial interpretation. Moreover, petitioners insist that although the statutes do not define the term "funeral and burial services," such term must be understood in its plain and ordinary meaning, which comprises the ceremony held for the deceased and the actual act of burying the remains in the ground.
On the other hand, respondent insists that there is an ambiguity in the law and the IRR that needs judicial determination. Respondent maintains that interment services are not covered under RA 7432, as amended by RA 9257 and RA 9994, since there is no specific provision in RA 9994 and its IRR that allows the 20% discount for interment services.
RULING: "We grant the Petition."
Interment services are covered under RA 7432, subject to a 20% discount on funeral and burial services for the death of senior citizens.
Love and respect for the elderly are deeply entrenched in our culture and form part of the very fabric of our society. So much so that the duty to care for the elderly is enshrined in no less than our Constitution¹
Interment services are covered by the 20% discount on funeral and burial expenses provided by law |
Having established the rationale for the 20% discount privileges granted to senior citizens as well as the shared duty of the State, the family, and the community to care for its elderly members, We will now elucidate on the scope of the services within the purview of the statutorily mandated 20% discount on funeral and burial services for the death of senior citizens.
Both RA 9257 and RA 9994, in amending RA 7432, do not provide for an exact definition of the term "funeral and burial services." Notably, the said laws likewise do not limit the scope of the services falling under "funeral and burial services." Indeed, as stated by Associate Justice Amy C. Lazaro-Javier in her Concurring Opinion, absent a clear legislative intent to the contrary, it would be unreasonable to infer that Congress intended to differentiate between the deceased's final solace for purposes of granting the 20% discount.
It is a well-settled rule that words of a statute would be interpreted in their natural, plain, and ordinary acceptation and the signification that they have in common use, unless it is evident that the legislature intended a technical or special legal. meaning to those words.51 The term burial is commonly understood to mean the act of placing a dead body in a grave or tomb,52 or the ceremony performed when this is done.
Thus, the RTC undoubtedly erred in its strict interpretation of the IRR of RA 9994 and ruling that interment services are not entitled to the 20% discount. The exclusion of interment services from the coverage of the statutorily mandated senior citizen discount is not provided in the law. Corollary, the IRR, which does not expressly exclude interment services, cannot be interpreted to support the conclusion of the RTC. Indeed, a law cannot be amended by a mere regulation, and the administrative agency issuing the regulation may not enlarge, alter, or restrict the provisions of the law it administers.60
As aptly stated by former United States President Ronald Reagan,
"[f]or all they have achieved throughout life and for all they continue to accomplish, we owe older citizens our thanks and a heartfelt salute."61 To show our gratitude, esteem and respect to our senior citizens, who have enriched our society with their valuable service, wisdom, knowledge and experience, it is only just that we grant them all the benefits that they deserve not only during their lifetime but even when they are finally laid to rest. This is our shared duty. The Congress did its part, now it is time to do ours.
FOOTNOTES
1 CONSTITUTION, Article XV, Sec. 4. provides:
SEC. 4. The family has the duty to care for its elderly members but the State may also do so through just programs of social security.
52 Merriam-Webster. (visited 03 March 2023).
61 The American Presidency Project. (visited 03 March)
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