G.R. No. L-57387 December 10, 1987
UNIVERSITY OF THE EAST, petitioner, vs. UNIVERSITY OF THE EAST FACULTY ASSOCIATION (UEFA) and THE PRESIDENTIAL EXECUTIVE ASSISTANT, respondents.

FACTS

This case involves the execution of a final and executory Supreme Court Decision dated September 30, 1982, concerning a labor dispute over the distribution of incremental tuition fee proceeds under Presidential Decree No. 451. Following the decision, the parties attempted to implement it but failed to agree on the proper computation of amounts due. UEFA filed a Motion for Execution, claiming money was due for new teachers and differential pays. UE opposed, asserting an overpayment of approximately P7.5 million, arguing its total disbursements to employees exceeded the 60% incremental proceeds. The Second Division granted execution. The City Sheriff subsequently levied and sold UE properties, including real properties comprising its Recto and Caloocan campuses, to UEFA. UE redeemed some properties but filed various pleadings contesting the execution’s correctness, claiming overpayment and praying for an equitable set-off. UEFA countered, arguing any overpayment claim constituted a separate cause of action and prayed for further execution for alleged unincorporated salary increases and benefits.

ISSUE

Whether the execution conducted by the City Sheriff conformed to the final and executory Supreme Court Decision of September 30, 1982, and how the amounts due to the faculty should be properly computed.

RULING

The Supreme Court found the execution improper and ordered a recomputation. The Court clarified that its final decision affirmed a Malacañang decision with three key components: (1) salary increases from collective bargaining are chargeable against the faculty’s 60% share of incremental tuition proceeds; (2) allowances and benefits are not chargeable against that share if the school has other resources, a question of fact; and (3) the starting pay of new teachers must reflect their share in past tuition increases. The Court ruled that the City Sheriff exceeded his authority by executing beyond the specific parameters of the affirmed decision, particularly by unilaterally awarding shares from tuition increases from 1974 to 1983, which was not authorized. The writ of execution must be strictly confined to enforcing the contractual rights defined in the decision for the specific period (June 1, 1978 to May 31, 1981). Consequently, the Court ordered the Department of Labor and Employment to recompute the amount due to UEFA based on precise guidelines, distinguishing between salary increases (chargeable to the 60% share) and allowances/benefits (not chargeable if other resources exist), and properly calculating the starting pay for new teachers. The motions for withdrawal of the deposited funds were denied pending this official recomputation.