G.R. No. 130546 - People vs. Flores

Petitioner: Anacleto Alzate, in his official capacity as Principal of the South Provincial High School in Agoo, La Union.
Respondents:

Benigno Aldana, in his official capacity as Director of Public Schools.
Zacarias G. De Vera, in his official capacity as Division Superintendent of Schools for La Union.

Petitioner’s claim is founded on the provisions of Section 4, paragraphs (a) and (b) of Republic Act No. 842 (Public School Salary Act of 1953).
He asserted that, considering his 24 years of service in the Bureau of Public Schools in various capacities—with his latest role being that of a secondary school principal—he was entitled:

To an automatic salary increase of 4 rates (1 rate for every 5 years of service) after his salary was adjusted to the minimum.
To an additional increase of 1 rate for having passed the examination for Superintendent of Private Schools administered by the Civil Service Commission.

On December 20, 1957, petitioner wrote to the Director of Public Schools to claim his rightful salary adjustment.
The Director replied on March 10, 1958, denying the petition on two grounds:

Only his actual years of service as a secondary principal (amounting to 9 years, 8 months, and 15 days) were considered, which qualified him for only one rate of increase.
The examination he passed pertained to the Bureau of Private Schools, not entitling him to the additional benefit under paragraph (b) of the Act.

Subsequently, on May 17, 1958, petitioner filed a request for reconsideration, citing a Secretary of Justice opinion (Op. No. 144, S-1956), which argued that all years of service in the educational branch should be considered, not only those in the current position.
Despite the request for reconsideration, no immediate ruling was given, causing petitioner to fear that the funds for salary adjustment—approximated at P840.00 as recommended in a negotiated agreement—might revert to the Government due to the fiscal year ending on June 30, 1958.

On June 11, 1958, petitioner filed a mandamus petition with the Court of First Instance of La Union.
The purpose was to compel the respondents to adjust his salary based on RA 842, motivated by:

The urgency to secure the appropriation before the fiscal deadline (June 30, 1958).
The possibility that any delay in the administrative process might result in the reversion of the funds appropriated for salary adjustments to the general fund.

Following a preliminary hearing on June 27, 1958, a temporary agreement was reached where:

The Director of Public Schools agreed in open court to recommend the commitment of the sum of P840.00 to accounts payable by June 30, 1958.
As a result, petitioner desisted from seeking a writ of preliminary mandatory injunction.

The absence of a cause of action against them.
The claim that petitioner had not exhausted all available administrative remedies.

On July 31, 1958, the Court of First Instance dismissed the petition on the ground that it was premature, as not all administrative remedies had been exhausted, though the dismissal was without prejudice to petitioner’s rights.

The critical issue was whether petitioner’s filing of a mandamus action was premature without having exhausted all available administrative remedies.
Whether the non-exhaustion of administrative remedies nullified the cause of action.

The petition was timely motivated by the fiscal year ending on June 30, 1958 and the impending reversion of funds.
The necessity to ensure that the sum appropriated under Republic Act No. 2042 for salary adjustments was not lost, thereby justifying an early resort to judicial action.

Whether there was a sufficient legal basis (cause of action) in light of the pending administrative reconsideration regarding the adjustment of salary.
The merits of petitioner's contention that delaying judicial action until all administrative processes were completed would effectively nullify his remedy.