GR 109977; (October, 1997) (Digest)
G.R. No. 109977 September 5, 1997
UNIVERSITY OF PANGASINAN, petitioner, vs. HONORABLE MA. NIEVES R. CONFESOR, in her official capacity as the Secretary of Department of Labor and Employment, and UNIVERSITY OF PANGASINAN FACULTY UNION, respondents.
FACTS
On August 7, 1986, the University of Pangasinan Faculty Union presented its demands to the University of Pangasinan. After conciliation failed, the Union went on strike on September 15, 1986. The University questioned the strike’s legality, and a Return-to-Work Order was issued on September 18, 1986. The Regional Director initially recommended dismissing salary differential claims for school years 1974-1981 due to prescription and allowing claims for 1982-1983 to 1987-1988, chargeable against 60% of incremental tuition fee proceeds. On October 5, 1989, the Secretary of Labor ordered a recomputation of salary differentials. After several recomputations, a final amount of P6,840,700.15 was determined, and Secretary Ruben Torres ordered its payment on October 10, 1991. The University’s motions for reconsideration were denied, prompting this petition for certiorari. The University argued that the Secretary committed grave abuse of discretion by misapplying laws (P.D. No. 451 and B.P. Blg. 232) regarding the use of incremental tuition fee proceeds and by allowing prescribed claims from 1974-1981.
ISSUE
1. Whether the Secretary of Labor committed grave abuse of discretion in ruling that the 60% incremental proceeds from tuition fee increases should be used exclusively for salary increases, excluding allowances and benefits.
2. Whether the Secretary of Labor committed grave abuse of discretion in allowing monetary claims for salary differentials covering school years 1974-1975 to 1980-1981 despite prescription.
RULING
1. Yes. The Supreme Court ruled that the Secretary of Labor committed grave abuse of discretion. Under P.D. No. 451, the 60% incremental proceeds were initially dedicated entirely to salary increases. However, B.P. Blg. 232 (the Education Act of 1982), which repealed P.D. No. 451, and subsequent implementing rules and regulations (e.g., MEC Order No. 23, s. 1983; DECS Order No. 37, s. 1987) expressly permitted the allocation of the 60% incremental proceeds for salaries, wages, allowances, and fringe benefits. Therefore, the University’s contention that the proceeds should not be for salary increases alone was legally correct.
2. Yes. The Supreme Court ruled that the Secretary of Labor committed grave abuse of discretion by including claims for school years 1974-1981. Article 291 (now 292) of the Labor Code prescribes money claims arising from employer-employee relations within three years from the time the cause of action accrues. The claims for 1974-1981, filed only in 1986, had clearly prescribed. The recomputation erroneously incorporated this prescribed period.
The petition was GRANTED. The decision of the Secretary of Labor was MODIFIED by excluding the prescribed claims from school years 1974 to 1981. The case was remanded to the Regional Director for recomputation of claims chargeable against the 60% incremental tuition fee proceeds, in accordance with the modifications.