GR L 65585; (September, 1984) (Digest)
G.R. No. L-65585 September 28, 1984
SAINT LOUIS FACULTY CLUB, represented by President WILMA DEL PRADO, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION and SAINT LOUIS UNIVERSITY, respondents.
FACTS
Saint Louis University applied for and was granted a 15% tuition fee increase for the 1976-77 and 1977-78 school years, citing the need to fund the 13th month pay as a primary justification. From the incremental proceeds, the University allocated substantial portions to cover the 13th month pay for its employees for the years 1975 and 1976, alongside other benefits and salary increases. The Saint Louis Faculty Club contested this allocation before the Labor Arbiter, arguing that the 13th month pay should not be charged against the 60% of incremental proceeds mandated by Presidential Decree No. 451 for salary increases. The Labor Arbiter ruled that the University had substantially complied with the law, considering the 13th month pay as a form of added compensation. This decision was affirmed by the National Labor Relations Commission (NLRC), prompting the Faculty Club to elevate the case to the Supreme Court.
ISSUE
Whether the 13th month pay, which is a benefit mandated by law, should be charged against the 60% of incremental tuition fee proceeds allocated for salary increases under P.D. No. 451.
RULING
The Supreme Court granted the petition and reversed the NLRC resolution. The Court held that the 13th month pay, being a benefit mandated by law (Presidential Decree No. 851), should not be charged against the 60% of incremental tuition proceeds allocated for salary increases under Section 3(a) of P.D. No. 451. Citing its prior ruling in University of the East vs. University of the East Faculty Association, the Court clarified that allowances and benefits required by law or collective bargaining agreements must be charged against the “return on investments” portion (capped at 12%) or other funds, not the 60% earmarked specifically for salary increases. The Court found it strange that the NLRC was not abreast of this settled doctrine. Consequently, the University was ordered to pay the petitioner the sum of P499,100.00 as due salary increases from the correct 60% allocation for the relevant school years, plus attorney’s fees and costs.