Senior Citizen Discount on Funeral Services Includes Interment, SC Rules

The Supreme Court has settled a question that affects every Filipino family: does the 20% senior citizen discount on funeral and burial services cover interment—the actual burial itself? In Republic v. Pryce Corporation, Inc. (G.R. No. 243133, March 8, 2023), the Court ruled yes, holding that interment services are included in the statutory discount. The decision clarifies the scope of a benefit that grieving families can claim during one of life's most difficult moments.

The Case

Pryce Corporation, a company selling memorial lots and offering interment services, filed a petition for declaratory relief before the Regional Trial Court of Misamis Oriental. The company asked the court to determine whether Section 4(a) of Republic Act No. 7432, as amended by RA 9257 and RA 9994 (the Expanded Senior Citizens Act), includes interment services in the 20% discount on funeral and burial services.

Pryce argued that interment services were not among those entitled to the discount. The government, through the Office of the Solicitor General, countered that the term "funeral and burial services" should be understood in its plain and ordinary meaning, which includes the actual act of burying the deceased.

The RTC sided with Pryce, ruling that the Implementing Rules and Regulations (IRR) of RA 9994 only mentioned specific services—purchase of casket or urn, embalming, hospital morgue, and transport of the body—and did not include interment. The government appealed to the Supreme Court.

The Issue

The sole legal question was whether interment services fall within the coverage of the 20% discount on funeral and burial services for the death of senior citizens under RA 7432, as amended.

The Ruling

The Supreme Court granted the government's petition and set aside the RTC resolutions. The Court held that interment services are covered by the 20% discount.

The Court reasoned that neither RA 9257 nor RA 9994 provides an exact definition of "funeral and burial services," nor do they limit the scope of services falling under that term. Applying the rule that words in a statute are interpreted in their plain and ordinary acceptation, the Court noted that "burial" is commonly understood as the act of placing a dead body in a grave or tomb. Black's Law Dictionary defines burial as the "act of depositing a dead body in the earth, in the tomb or vault." Interment—digging the grave, concreting the gravesite, and other services during the actual burial—is therefore necessarily included.

The Court also rejected the RTC's strict reading of the IRR. The IRR of RA 9994 lists covered expenses but uses language indicating that the enumeration is not exclusive. The provision specifically excludes only two items—obituary publication and the cost of the memorial lot—and does not mention interment services.

Significantly, the Court emphasized that the IRR requires the rules to be construed liberally and in favor of senior citizens. A law cannot be amended by a mere regulation, and an administrative agency may not enlarge, alter, or restrict the provisions of the law it administers.

Why This Matters

The decision affirms the state's policy of caring for senior citizens not only during their lifetime but even after death. The Court stressed that the senior citizen discount is a valid exercise of police power, intended to improve the welfare of the elderly who are less likely to be gainfully employed and more prone to illnesses. The discount serves to honor senior citizens who spent their productive years contributing to national development.

Practical Takeaways

• The 20% senior citizen discount applies to interment services, including digging the grave, concreting the gravesite, and other services performed during the actual burial.
• The discount covers funeral and burial expenses such as casket or urn purchase, embalming, cremation, viewing or wake costs, pick-up from the hospital morgue, and transport of the body to the burial site.
• The discount does not cover obituary publication and the cost of the memorial lot itself.
• The beneficiary or any person who shoulders the funeral and burial expenses may claim the discount upon presentation of the senior citizen's death certificate.
• Funeral parlors and similar establishments that grant the discount may claim it as a tax deduction based on the cost of goods sold or services rendered.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.