Title
Alzate vs. Aldana
Case
G.R. No. L-14407
Decision Date
Feb 29, 1960
A school principal sought mandamus for salary adjustment under RA 842, claiming 24 years of service. The court ruled urgency justified bypassing administrative remedies due to impending fund reversion.
Font Size:

Case Digest (G.R. No. L-14407)

Facts:

  1. Background of the Case: Anacleto Alzate, the Principal of the South Provincial High School in Agoo, La Union, filed a petition for mandamus to compel the Director of Public Schools and the Division Superintendent of Schools for La Union to adjust his salary under Section 4, paragraphs (a) and (b) of Republic Act No. 842 (Public School Salary Act of 1953).

  2. Petitioner’s Claim: Alzate claimed entitlement to an automatic salary increase based on his 24 years of service in the Bureau of Public Schools. He argued that under Section 4(a), he was entitled to 4 rates (1 rate for every 5 years of service) and an additional 1 rate under Section 4(b) for passing the examination for Superintendent of Private Schools.

  3. Respondents’ Denial: The Director of Public Schools denied the claim, stating that only Alzate’s 9 years, 8 months, and 15 days as a secondary principal would be considered for the adjustment. The additional rate under Section 4(b) was also denied, as the examination was for the Bureau of Private Schools, not Public Schools.

  4. Request for Reconsideration: Alzate sought reconsideration, citing a Justice Secretary’s opinion that the length of service in the educational branch, not just the current position, should be considered. However, no final ruling was made on his request.

  5. Filing of Mandamus: Fearing that the funds for salary adjustments would revert to the general fund by June 30, 1958, Alzate filed a mandamus petition on June 11, 1958.

  6. Court’s Initial Action: The court facilitated an agreement where the Director of Public Schools would recommend the commitment of P840 for Alzate’s claim before June 30, 1958, to prevent reversion of funds.

  7. Motion to Dismiss: Respondents moved to dismiss the petition, arguing that Alzate failed to exhaust administrative remedies, and the court lacked jurisdiction. The lower court dismissed the petition as premature.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Exhaustion of Administrative Remedies: While the exhaustion of administrative remedies is generally required, there are exceptions when urgent circumstances make it impractical. In this case, the impending reversion of funds by June 30, 1958, created a situation of urgency.

  2. Sufficient Cause of Action: The petitioner had a valid claim, and the agreement to commit funds before the fiscal year ended supported the necessity of immediate judicial intervention.

  3. Recognition of Urgency: The court recognized the validity of the petitioner’s concerns, as evidenced by the agreement facilitated by the court to prevent the reversion of funds.


Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.