Mendoza v.

Dizon (1946)
Doctrines: Facts: [Yung case in Spanish. Sorry kung ang labo nung digest. Kasi Spanish talaga </3] Juan M. Cuevas is the legitimate child of Balbina Mendoza. In 1932, Cuevas married Florence Cocadiz. They divorced in 1944. Cuevas died. Mendoza was the nearest relative to the deceased. In December 1945, the President of the Philippine Commonwealth issued Administrative Order No. 27. The AO provided that officials and employees of the national government who had been in active service in December 8, 1941, have been or not called to return to their jobs after their liberation would get bonuses or gratuities. Mendoza presented documents to Auditor General Dizon to show that she is the nearest relative in order to get the money that shouldve gone to her deceased son. At this point, Cocadiz had not appeared officially before Dizon. Dizon sought the opinion of the Justice Department, on whether the divorced wife referred to here has any right to the gratuity of the deceased husband under the AO, considering that the gratuity is equivalent to the salaries for the months of January and February, 1942. The Auditor General then decided that since the gratuity of Cuevas consisted of his salary for January and February 1942, the money should be part of the conjugal estate of Cuevas and Cocadiz. The Auditor General held that half of the money should go to Mendoza and half to Cocadiz. Mendoza appealed. Issues: 1. W/N the gratuity payable to Cuevas belongs to his vacant inheritance or be considered goods belonging the acquisitions of the deceased and his wife? Held/Ratio: 1. YES, so that we have a categorical answer. Gratuity means something that is given and received by lucrative title. The term gratuity was deliberately used. The use of such term shows the intention to limit the scope of the privilege strictly to the letter of the law. The gratuity corresponds to salaries. Claiming that the divorced wife is entitled to half of the money because the spouses were not even legally divorced at the time has absolutely no foundation. There is nothing in AO 27 that says gratuities are specifically granted to the months previously mentioned. It seems superfluous to say that the decision in the said case has nothing to do with the question of whether officials and Commonwealth Government employees in active service at the outbreak of war had passed or back wages, whether or not during enemy occupation, or the other questions if the Government of the Republic [pays their salary obligations]. Hence, the SC decided that Mendoza should get the total amount of the gratuity, subject to any valid claim against the property of the deceased. Origin and Development of Administrative Law Recognition as a Distinct Category of Law (topic for this case)