G.R. No. L-17620 - Far Eastern University vs. Court of Industrial Relations

Tomas N. Aguirre began his tenure at the Far Eastern University (FEU) in 1948 as a faculty member.
Initially employed at P6.00 per hour, he later taught at the Boys High School Department at a rate of P30.00 per class, earning approximately P500.00 to P600.00 a month.
In June 1953, Aguirre joined the Philippine Association of Colleges and University Professors (PACUP), a legitimate labor organization.

Upon orders from PACUP’s president, Jose M. Fernandez, Aguirre actively campaigned for union membership.
His efforts resulted in influencing seven faculty members to join the union.
His union activities created an environment of apprehension among other faculty members, who feared retaliation from the university if they affiliated with the union.

In 1953, the university formed a committee to classify its over four hundred faculty members.

Ninety-six were classified as full time instructors.
Aguirre was designated as a full time instructor in the Institute of Education, earning a fixed compensation of P450.00 per month effective September 1, 1953.

Between December 1953 and May 1954, Aguirre’s earnings reflected his full time status; however, in June 1954, he was no longer given teaching assignments.
Aguirre contended that the absence of assignments was due to his union activities, while the university attributed this to decreased enrollment, particularly in the Filipino Language classes.

Other faculty members, including part time professors (e.g., Regalado, Mendoza) with less seniority received assignments despite Aguirre’s longer service and full time status.
The dean’s testimony confirmed that criteria such as length of service, experience, and professional growth were considered when assigning subjects.
The imbalance between Aguirre’s treatment and that of his peers suggested a motive beyond genuine enrollment concerns.

Aguirre filed charges against the university; subsequently, the Department of Education and other governmental agencies ordered the university to pay salary differential and back wages due to the reduction in his teaching load.
Decisions by the Director of Private Schools (November 5, 1954), the Secretary of Education (June 22, 1955), and the Executive Secretary (December 8, 1956) were rendered in Aguirre’s favor, emphasizing the reduction in assignments and corresponding salary loss.
Despite these orders, the university continued its adverse employment action against Aguirre.

Aguirre secured teaching at the Philippine College of Commerce from June 1955 and gained permanent employment at the Central Bank of the Philippines on November 17, 1955, with subsequent salary adjustments.
The university argued that Aguirre’s new employment positions were substantial equivalents to his former teaching role.
However, evidence indicated significant differences:

The teaching position at FEU provided P5,400.00 per annum compared to a lower wage rate at the Central Bank.
His work at the Central Bank involved clerical tasks with eight-hour workdays, unlike his professorial teaching role which had a maximum of five teaching hours daily.
The career prospects and future growth as an instructor, especially in Tagalog—a subject in which Aguirre specialized—were far superior at FEU than the research position at the bank.

Judge Arsenio I. Martinez of the Court of Industrial Relations ruled that the university committed an unfair labor practice by reducing Aguirre’s load and salary.
Initially, the decision ordered the payment of wage differential and back wages without reinstating Aguirre, on the basis that his new employment was seen as substantially equivalent.
Later, en banc modifications modified the decision to include his reinstatement, citing that the employment at the Central Bank and the Philippine College of Commerce was not substantially equivalent to his prior status as a full time instructor at FEU.

Determination of the True Motive Behind the Reduction in Teaching Assignments

Whether the refusal to give Aguirre teaching assignments in June 1954 was due to decreased enrollment as claimed by the university or was an act of retaliation stemming from his union activities.

Whether Aguirre’s subsequent employment at the Central Bank of the Philippines (and his part time teaching at the Philippine College of Commerce) can be considered substantially equivalent to his previous position as a full time instructor at FEU.
The impact of differences in wage rates, working hours, and the nature of job responsibilities on the equivalence determination.

Whether Aguirre is entitled to wage differential and back wages due to the reduction of his teaching load and salary.
Whether the proper remedy includes reinstatement to his former position at FEU, despite his subsequent permanent employment elsewhere.