Title
Angelicum Faculty and Employees Association vs. National Labor Relations Commission
Case
G.R. No. 121304
Decision Date
Mar 19, 1998
AFEA demanded 70% of ASI's tuition fee increase for wage hikes; SC ruled provisional wage increase creditable, reducing AFEA's claim to P105,573.20.
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Case Digest (G.R. No. 121304)

Facts:

  1. Parties Involved:

    • Petitioner: Angelicum Faculty and Employees Association (AFEA), a legitimate labor organization representing teaching and non-teaching employees of Angelicum School, Inc. (ASI).
    • Respondents: Angelicum School, Inc. (ASI), a religious educational institution, with Tamerlane Lana as School Director and Alfonso Loreto as Assistant Director for Finance.
  2. Wage Orders and Tuition Fee Increases:

    • On 15 October 1990, Wage Order No. NCR-01 was issued, increasing the minimum wage by P17.00 per day for workers earning not more than P125.00 daily.
    • On 20 December 1990, Wage Order No. NCR-02 was issued, granting an additional P12.00 per day provisional wage increase for employees earning up to P142.00 daily.
    • In response, the Department of Education, Culture, and Sports (DECS) issued DECS Order No. 30, Series of 1991, allowing schools to increase tuition fees to cover wage increases. ASI notified DECS of a P226.50 tuition fee increase and an additional P226.50 emergency tuition fee assessment (ETFA) for the 1991-1992 school year, totaling P1,526,043.76.
  3. Dispute Over Distribution of Tuition Fee Increase:

    • AFEA demanded 70% of the tuition fee increase (P534,115.32) for salary increases and benefits, citing Section 5, Paragraph 2 of RA No. 6728 and the Collective Bargaining Agreement (CBA).
    • ASI argued that it had already complied with RA No. 6728 by granting salary increases totaling P1,545,777.15, which included retroactive payments for the provisional wage increase and other benefits.
    • AFEA objected, claiming that the mandated wage increases should not be credited against the tuition fee increase.
  4. Labor Arbiter and NLRC Decisions:

    • The Labor Arbiter ruled in favor of AFEA, ordering ASI to pay P530,410.53 (70% of the tuition fee increase) plus attorney’s fees.
    • The National Labor Relations Commission (NLRC) modified the decision, crediting the provisional wage increase against the 70% share and reducing the amount due to AFEA to P114,573.20.

Issue:

  1. Whether the provisional wage increase under Wage Order No. NCR-02 can be credited against the 70% share of the tuition fee increase mandated by RA No. 6728.
  2. Whether the Collective Bargaining Agreement (CBA) provisions on salary increases and benefits apply to the tuition fee increase.
  3. Whether the NLRC erred in reducing the amount due to AFEA by crediting the provisional wage increase.

Ruling:

The Supreme Court denied the petition and affirmed the NLRC’s decision with modifications. The Court held that:

  1. The provisional wage increase under Wage Order No. NCR-02 could be credited against the 70% share of the tuition fee increase, as DECS Order No. 30, Series of 1991, authorized tuition fee increases to mitigate the effects of wage increases.
  2. The CBA provisions on salary increases and benefits did not apply to the tuition fee increase, as the increase was not applied for or approved by DECS but was merely notified.
  3. The NLRC correctly excluded the CBA-mandated increases (re-ranking, change in pay class, and SSS/PERAA/MEDICARE) from the computation but made an error in the total amount due. The corrected amount due to AFEA was P105,573.20, with attorney’s fees reduced to P10,557.32.

Ratio:

  1. Crediting Wage Increases Against Tuition Fee Increase:

    • The Court ruled that DECS Order No. 30, Series of 1991, allowed schools to increase tuition fees to cover wage increases mandated by regional wage orders. Therefore, crediting the provisional wage increase against the 70% share of the tuition fee increase was proper.
  2. CBA Provisions and Tuition Fee Increase:

    • The Court found that the CBA provisions on salary increases and benefits did not apply to the tuition fee increase, as the increase was not applied for or approved by DECS but was merely notified. The proper provision was Section 4, Article X of the CBA, which mandated compliance with government-ordered wage increases.
  3. Computation of Amount Due:

    • The Court corrected the NLRC’s computation, ruling that the total amount due to AFEA was P105,573.20, after subtracting the provisional wage increase from the 70% share of the tuition fee increase and the ETFA. The attorney’s fees were accordingly reduced to P10,557.32.


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