G.R. No. 82312 April 19, 1989
MANUEL L. QUEZON UNIVERSITY ASSOCIATION, ET AL., petitioners, vs. MANUEL L. QUEZON EDUCATIONAL INSTITUTION, INC. (MLQ UNIVERSITY), HON. DIONISIO C. DELA SERNA, UNDERSECRETARY OF LABOR AND EMPLOYMENT, respondents.

FACTS

The petitioners, faculty members of MLQ University, filed a complaint on April 24, 1979, for unpaid salary differentials under P.D. No. 451. This decree mandated that 60% of authorized tuition fee increases be allocated for salary increases. They alleged the university paid only P0.50 per lecture hour instead of the computed P2.11-P2.15. The Regional Director, in an Order dated June 15, 1983, partially granted the claim but ruled that amounts accruing more than three years before the complaint’s filing had prescribed. He awarded differentials only from April 24, 1976, for the original complainants, and from January 25, 1977, for intervenors.
Petitioners received this order on June 22, 1983, and filed a motion for reconsideration on July 25, 1983. Deputy Minister Leogardo initially dismissed this motion as a belated appeal on December 12, 1984. However, upon petitioners’ motion for reconsideration, he reversed himself in an Order dated December 6, 1985, reinstating the appeal and substantially increasing the awarded differentials. Both parties moved for reconsideration of this new order.

ISSUE

The primary issues were: (1) whether the petitioners’ appeal from the Regional Director’s 1983 Order was timely filed; (2) whether the Undersecretary of Labor gravely abused his discretion in annulling the 1985 Order that increased the awards; and (3) whether the claims for earlier school years had prescribed.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. On procedural grounds, the Court upheld respondent Undersecretary Dela Serna’s finding that the petitioners’ motion for reconsideration of the June 15, 1983, Order was filed beyond the ten-day reglementary period under Article 223 of the Labor Code. The period ran from receipt on June 22, 1983, making the July 25, 1983, filing late. Consequently, the June 15, 1983, Order became final and unappealable. Deputy Minister Leogardo’s subsequent December 6, 1985, Order, which modified the final order, was correctly annulled by Undersecretary Dela Serna for having been issued without jurisdiction.
On the substantive issue of prescription, the Court affirmed that the three-year prescriptive period under Article 292 (now 291) of the Labor Code governs money claims arising from employer-employee relations, including claims under P.D. 451. The Court rejected the application of the Civil Code’s ten-year period, noting the Labor Code provision is a special law. While petitioners made a written demand on November 4, 1974, which interrupted prescription, the period resumed and expired on November 4, 1977. Their complaint, filed on April 24, 1979, was therefore barred for claims accruing before April 24, 1976. The Court also found no error in excluding the twenty-five faculty members who voluntarily withdrew their claims.