San Agustin Elementary School Teachers' Association

DM NO. 862, S. 2026 - EXTENSION OF SUBMISSION DEADLINE FOR TEACHER ELECTRONIC IPCRF (E-IPCRF) FOR SY 2025-2026.pdf

FD NO. 242, S. 2026 - ADVISORY - EXTENSION OF SUBMISSION DEADLINE FOR TEACHER ELECTRONIC IPCRF (E-IPCRF) FOR SY 2025-2026.pdf

The (SC) has ruled that the Government Service Insurance System (GSIS) exceeded its authority when it issued a rule that excluded secondary beneficiaries from receiving survivorship benefits of deceased members who had at least three but less than 15 years of service.

In a Decision written by Associate Justice Henri Jean Paul B. Inting, the SC’s Third Division declared Section 24.2.2 of the 𝘙𝘦𝘷𝘪𝘴𝘦𝘥 𝘐𝘮𝘱𝘭𝘦𝘮𝘦𝘯𝘵𝘪𝘯𝘨 𝘙𝘶𝘭𝘦𝘴 𝘢𝘯𝘥 𝘙𝘦𝘨𝘶𝘭𝘢𝘵𝘪𝘰𝘯𝘴 (𝘐𝘙𝘙) of Republic Act No. 8291, or 𝘛𝘩𝘦 𝘎𝘰𝘷𝘦𝘳𝘯𝘮𝘦𝘯𝘵 𝘚𝘦𝘳𝘷𝘪𝘤𝘦 𝘐𝘯𝘴𝘶𝘳𝘢𝘯𝘤𝘦 𝘈𝘤𝘵 𝘰𝘧 1997 (𝘎𝘚𝘐𝘚 𝘈𝘤𝘵), 𝘶𝘭𝘵𝘳𝘢 𝘷𝘪𝘳𝘦𝘴 or beyond the GSIS’ rule-making authority.

As a result, the GSIS is barred from enforcing the provision to the extent that it conflicts with Section 21(c) of the law.

The case arose from the application of Petronilo B. Laroco (Laroco) for survivorship benefits following the death of his daughter, Cristie. She was a public school teacher with 13 years of government service and had paid GSIS premiums for 12 years. She died single and had no children.

The GSIS rejected the application. Under Section 24.2 of the IRR, Laroco was ineligible for survivorship benefits because he was not a primary beneficiary.

The GSIS held that secondary beneficiaries qualify for survivorship only if the deceased member had served at least 15 years in the government. Since Cristie had only 13 years of service, only her primary beneficiaries—such as her spouse or children—were entitled to survivorship benefits.

Ruling in Laroco’s favor, the SC pointed out that Section 24.2.2 of the IRR conflicts with the law because it adds a new requirement—limiting survivorship benefits for secondary beneficiaries only to cases where the deceased member served at least 15 years.

Under the 𝘎𝘚𝘐𝘚 𝘈𝘤𝘵, a secondary beneficiary is entitled to survivorship benefits if: (1) there is no primary beneficiary; (2) the secondary beneficiary meets the dependency requisites under the law; (3) the member was in government service at the time of their death; and (4) the member has rendered at least three years of service.

The SC stressed that although the GSIS had good intentions to address the “unequal situation” under the law, it cannot simply change the 𝘎𝘚𝘐𝘚 𝘈𝘤𝘵 through a mere administrative issuance.

The three-year government service requirement for survivorship benefit under Section 21 might be, as argued by the GSIS, unfair and disadvantageous to other members who are required to render at least 15 years of service before qualifying for pension, but this is what is provided in the law.

The SC remanded the case to the GSIS Committee on Claims for the computation of the benefits payable to Laroco.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=167839.

Read the full text of the Decision at http://sc.judiciary.gov.ph/?p=165811.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

IMPORTANT DATES FOR S.Y. 2026-2027
Three-Term School Calendar

TERM 1 (JUNE 8-SEPTEMBER 15, 2026

June 1–5, 2026 — Brigada Eskwela / Enrollment Period
June 8–11, 2026 — Opening Block: Start of Term 1
June 12, 2026 — Independence Day (Regular Holiday)

July 6, 2026 — First Teacher-Made Summative Test
July 28, 2026 — Second Teacher-Made Summative Test

August 21, 2026 — Ninoy Aquino Day (Non-Working Holiday)
August 28, 2026 — Term 1 Examination
August 31, 2026 — National Heroes Day (Regular Holiday)

September 1, 2026 — Term 1 Examination
September 2–15, 2026 — End-of-Term Block
September 2–8, 2026 — ARAL Program, Computation of Grades, Accomplishment of School Forms, & Co-/Extra-Curricular Activities
September 9, 2026 — PTA Meeting & Distribution of Report Cards
September 10–11, 2026 — INSET
September 10–15, 2026 — Wellness Break of Learners (Guided asynchronous learning experiences)
September 14–15, 2026 — Wellness Break of Teachers
September 15, 2026 — End of Term 1

Please be guided accordingly and stay updated for announcements.

Source: DepEd Order No. 009, s. 2026

ONLINE ORIENTATION CONFERENCE FOR THE CONDUCT OF INITIAL AND COMPARATIVE EVALUATION OF APPLICANTS FOR RECLASSIFICATION.pdf

DM NO. 541, S. 2026 - PRELIMINARY ACTIVITIES FOR THE CONDUCT OF INITIAL AND COMPARATIVE EVALUATION OF APPLICANTS FOR RECLASSIFICATION.pdf