GR 202097; (July, 2019) (Digest)
G.R. No. 202097. July 3, 2019.
DEPARTMENT OF EDUCATION, Petitioner, vs. RIZAL TEACHERS KILUSANG BAYAN FOR CREDIT, INC., represented by TOMAS L. ODULLO, Respondent.
FACTS
The Department of Education (DepEd) implemented a payroll deduction scheme for loans obtained by public school teachers from accredited private lenders, including respondent Rizal Teachers Kilusang Bayan for Credit, Inc. (RTKBCI). DepEd would deduct loan payments from teachers’ salaries and remit them to RTKBCI, retaining a two percent administrative fee. In 2001, however, DepEd suspended the remittances and the deduction scheme for RTKBCI via a memorandum from Undersecretary Ernesto Pangan.
The suspension was prompted by numerous complaints from teachers alleging unauthorized and excessive deductions by RTKBCI, and possible connivance with DepEd personnel. Attached complaints detailed grievances where deductions far exceeded principal loan amounts, causing severe financial hardship. RTKBCI filed a petition for mandamus to compel DepEd to resume the deductions and remit the collected funds.
ISSUE
May the DepEd be compelled by a writ of mandamus to collect, via salary deductions, the loan payments of teachers and remit them to RTKBCI?
RULING
No. The Supreme Court ruled that mandamus does not lie to compel DepEd to continue the payroll deduction scheme. A writ of mandamus issues only to compel the performance of a ministerial duty that is clear, specific, and legally demandable. The Court found that DepEd’s act of implementing the salary deduction scheme for private lenders is not a ministerial duty but a discretionary function exercised under its administrative authority.
The legal logic is anchored on the nature of DepEd’s powers. The Court emphasized that DepEd, in establishing the deduction scheme, was exercising an administrative prerogative intended for the welfare of teachers. This prerogative inherently includes the authority to suspend or terminate the scheme upon finding valid grounds, such as the widespread complaints of abuse and excessive deductions which defeated the program’s beneficent purpose. Compelling DepEd to continue the scheme would interfere with its discretionary power to protect its employees from potential exploitation. Therefore, the suspension was a valid exercise of discretion, not a refusal to perform a ministerial act, making mandamus an improper remedy. The lower courts’ decisions granting the writ were reversed.