Case Digest (G.R. No. 204948)
Facts:
Development Bank of the Philippines v. Ronquillo, et al., G.R. No. 204948, September 07, 2020, Supreme Court Third Division, promulgated October 17, 2022, Gaerlan, J., writing for the Court.Petitioner Development Bank of the Philippines (DBP) faced a class claim by numerous former and current employees (respondents) for alleged unpaid back wages consisting of Cost of Living Allowance (COLA) and Amelioration Allowance (AA). DBP had earlier approved internal resolutions granting COLA (Executive Committee Resolution No. 0236, May 22, 1985; Board Resolution No. 0210, April 13, 1988). After Republic Act No. 6758 (Compensation and Position Classification Act of 1989) took effect on July 1, 1989, and pursuant to DBM Corporate Compensation Circular (CCC) No. 10 (Oct. 2, 1989), DBP discontinued COLA and AA payments.
In 1999 DBP offered an Early Retirement Incentive Program (ERIP) that included gratuities; some respondents availed themselves of ERIP and executed quitclaims. DBP later adopted Board Resolution No. 0137 (May 9, 2003) to grant COLA covering July 1, 1989 to February 28, 1999 for certain employees, and Board Resolution No. 0151 (Nov. 16, 2005) to grant AA to employees except retirees/resignees who waived claims. The DBM-CCC No. 10 had been declared ineffective for lack of publication in De Jesus v. Commission on Audit (1998).
Respondents repeatedly demanded payment; DBP denied liability (letter of June 4, 2008). On July 24, 2008 respondents filed a petition for writ of mandamus under Rule 65 in the Regional Trial Court (RTC) of Quezon City, Branch 98 (Special Civil Action No. Q-08-63099). On September 22, 2010 the RTC denied the petition as to those who availed ERIP (holding their quitclaims barred recovery) but granted relief to several other petitioners, ordering DBP to pay differentials, interest, attorney’s fees and costs.
Both parties appealed to the Court of Appeals (CA). In a decision promulgated June 6, 2012, the CA modified the RTC: it held ERIP participants were nevertheless entitled to COLA and AA (quitclaims ineffective to bar recovery), dismissed the petition for those still employed as of May 9, 2003 or Nov. 16, 2005 (because of DBP Resolutions Nos. 0137 and 0151), remanded to the RTC to determine employment status on those dates, and affirmed the award of attorney’s fees and costs. DBP’s motion for reconsideration was denied by CA resolution dated December 19, 2012.
DBP...(Subscriber-Only)
Issues:
- Is mandamus available to compel DBP to pay the claimed COLA and AA—i.e., do the respondents have a clear legal right and is DBP under a ministerial duty to pay?
- Were the COLA and AA integrated into standardized salaries upon the effectivity of R.A. No. 6758 (and thus no longer payable separately), and does the nullification of DBM-CCC No. 10 in De Jesus v. Commission on ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)