GR L 58870; (December, 1987) (Digest)
G.R. No. L-58870, L-68345, L-69224-25, 70832, L-76524, 76596 December 18, 1987
Cebu Institute of Technology, et al. vs. Hon. Blas Ople, et al.; Divine Word College of Legazpi vs. Hon. Vicente Leogardo, Jr., et al.; Far Eastern University Employees Labor Union vs. Far Eastern University, et al.; Gregorio T. Fabros, et al. vs. Hon. Jaime C. Laya, et al.; Jasmin Biscocho, et al. vs. Hon. Augusto Sanchez, et al.; Ricardo C. Valmonte, et al. vs. Hon. Augusto Sanchez, et al.
FACTS
These consolidated cases involve disputes between various private schools and their employees regarding the allocation of proceeds from tuition fee increases under Presidential Decree No. 451. The controversy centered on the interpretation of Section 3(a) of P.D. 451, which mandated that 60% of incremental tuition fee proceeds “is allocated for increase in salaries or wages” of faculty and employees. The schools contended that the 60% allocation could be used for any form of compensation, including allowances and benefits, while the employees argued it was reserved exclusively for direct salary or wage increases.
Subsequently, Batas Pambansa Blg. 232 (The Education Act of 1982) was enacted, containing a different provision in its Section 42 for the allocation of tuition fee increases. This raised the ancillary issue of which law governed allocations for increases collected after B.P. 232’s effectivity. The cases reached the Supreme Court to resolve these uniform legal questions.
ISSUE
The primary issue is whether the 60% portion of incremental tuition fee proceeds under P.D. 451 must be allocated exclusively for direct increases in the basic salary or wage, or if it may also cover allowances and other benefits. A secondary issue is determining the governing law for allocations after the passage of B.P. Blg. 232.
RULING
The Supreme Court ruled in favor of the employees for tuition increases collected during the effectivity of P.D. 451. The 60% incremental proceeds are allocated exclusively for increases in the basic salary or wage. The term “salaries or wages” in P.D. 451 refers to the basic compensation for services rendered, excluding allowances, bonuses, and other benefits. The law’s intent was to directly and immediately improve the economic lot of teaching and non-teaching personnel by augmenting their regular pay. Allowing the 60% to be used for other benefits would defeat this purpose and contravene the decree’s explicit language and protective objective.
Regarding the effect of B.P. Blg. 232, the Court held that it repealed P.D. 451. Therefore, for tuition fee increases collected on or after September 1, 1982, the allocation shall be governed by Section 42 of B.P. Blg. 232 and the implementing rules issued by the then Ministry of Education, Culture and Sports. The Court upheld the validity of MECS Order No. 25, which implemented B.P. Blg. 232’s provisions. Consequently, the specific dispositions in each consolidated case were made based on whether the claims arose from increments collected under the regime of P.D. 451 or B.P. Blg. 232.