G.R. No. 213730, June 23, 2021
Guagua National Colleges, Petitioner, vs. Guagua National Colleges Faculty Labor Union and Guagua National Colleges Non-Teaching and Maintenance Labor Union, Respondents.
FACTS
Petitioner Guagua National Colleges (GNC) implemented a 15% tuition fee increase for school year 2010-2011. From the net tuition fee incremental proceeds (TIP) of P4,579,923.00, it allocated 70% (P3,205,946.00) pursuant to Republic Act No. 6728, with a significant portion (P2,569,102.00) allocated to a retirement benefit fund contribution. Respondents, the faculty and non-teaching labor unions, demanded that the 70% TIP be allocated specifically to salary increases, citing Section 182(b) of the 2010 Revised Manual of Regulations for Private Schools in Basic Education, which states that tuition fee increases shall not be approved unless 70% of the proceeds is allocated for increase in salaries or wages. GNC maintained that RA 6728, which states the 70% shall go to “salaries, wages, allowances and other benefits,” is controlling and grants management discretion. The dispute was submitted to voluntary arbitration. The Voluntary Arbitrator ruled in favor of the unions, directing GNC to re-allocate the funds used for the retirement plan, interpreting that under DECS Order No. 15 (the implementing guideline for RA 6728), “other benefits” means “wage-related benefits” available while employed, which excludes a retirement plan. The Court of Appeals affirmed this decision. GNC elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in affirming the ruling that the allocation of a portion of the 70% tuition fee incremental proceeds to the employees’ retirement plan is not in accordance with Section 5(2) of RA 6728.
RULING
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the assailed CA Decision and Resolution. The allocation of a portion of the 70% net TIP for contribution to the retirement plan is VALID under Section 5(2) of RA 6728. The Court held that the plain and unambiguous text of RA 6728 states that the 70% shall go to “salaries, wages, allowances and other benefits.” The term “other benefits” is not qualified or restricted to “wage-related” benefits. Retirement benefits, which are monetary benefits received by employees, squarely fall within the general term “other benefits.” The Court found that DECS Order No. 15, which inserted the qualifier “wage-related” into the statutory term “other benefits,” constituted an addition to the law that was not intended by the legislature. An administrative issuance, such as DECS Order No. 15, cannot amend an act of Congress. Furthermore, the Court noted that the 2010 Revised Manual of Regulations, cited by the unions, was inapplicable as it pertained to basic education, while GNC is a tertiary institution. The law itself, RA 6728, does not prohibit sourcing retirement plan contributions from the 70% TIP.
