G.R. No. L-58870, L-68345, L-69224-25, L-70832, L-76521, L-76596 April 15, 1988
Cebu Institute of Technology, et al. vs. Hon. Blas Ople, et al. (Consolidated Cases)

FACTS

These consolidated cases originated from petitions filed by various private educational institutions and their faculty associations concerning the implementation of Presidential Decree No. 451 and Batas Pambansa Blg. 232. The core dispute involved the allocation of incremental tuition fee increases. PD 451 mandated that 60% of such increases be allocated exclusively for payment of salaries, wages, allowances, and other benefits of teaching and non-teaching personnel, except administrators. Subsequently, BP 232 (The Education Act of 1982) was enacted, providing a different framework for fund allocation and granting rule-making authority to the then Minister of Education, Culture and Sports (MECS).
The private schools contested the jurisdiction of the Labor Ministry and the validity of MECS implementing orders, arguing that BP 232 did not repeal PD 451 and that it constituted an undue delegation of legislative power. The faculty members, on the other hand, sought to enforce their monetary claims under the decrees. In its Decision dated December 18, 1987, the Court upheld the validity of BP 232 and the jurisdiction of labor authorities, leading to the filing of the present motions for reconsideration and clarification.

ISSUE

The primary issues for resolution in these motions were: (1) whether BP 232 repealed PD 451; (2) whether BP 232 constituted an undue delegation of legislative power; (3) the applicable prescriptive period for filing money claims arising from the tuition fee increases; and (4) the proper computation and allocation of the incremental proceeds, including ancillary matters like negotiation fees and attorney’s liens.

RULING

The Court denied the motions for reconsideration and issued clarifications. It reiterated its ruling that Section 42 of BP 232 expressly repealed PD 451. The Court found no undue delegation of legislative power, as BP 232 itself provided sufficient standards to guide the MECS Secretary in promulgating the necessary implementing rules and regulations.
On the crucial matter of prescription, the Court definitively ruled that claims for incremental proceeds are money claims arising from an employer-employee relationship. Consequently, Article 292 of the Labor Code, which prescribes a three-year period from the time the cause of action accrues, governs the filing of such claims. This prescriptive period applies to all schools involved in the consolidated cases.
The Court issued specific modifications and clarifications per case. In the Divine Word College case, claims prior to February 17, 1980, were declared prescribed. In the Far Eastern University case, claims for school year 1974-1975 were barred by prescription. The Court clarified that the 60% allotment under PD 451 applies only to the portion answering for increases in allowances and benefits. It also ordered the recomputation of liabilities based on the actual incremental proceeds collected and remanded the issue of attorney’s fees in the FEU case to the NLRC for settlement. The 10% negotiation fee payable to faculty associations was clarified to be computable only on the amount in excess of the 60% allocation and only for a specified three-year period.