Case Digest (G.R. No. 188492)
Facts:
Guagua National Colleges v. Court of Appeals, G.R. No. 188492, August 28, 2018, Supreme Court En Banc, Bersamin, J., writing for the Court.The petition arose from a labor dispute between private educational institution Guagua National Colleges (GNC) and its employees, represented by the GNC Faculty and Labor Union and the GNC Non-Teaching Maintenance Labor Union. Pursuant to Section 5(2) of R.A. No. 6728, GNC imposed a 7% tuition increase for school year 2006–2007 and, by Board action, diverted part of the resulting incremental proceeds to fund the retirement plan, which the unions challenged as a violation of the statute. The parties submitted the controversy to voluntary arbitration.
Voluntary Arbitrator Froilan M. Bacungan rendered a decision dated June 16, 2008 in favor of GNC, holding that retirement benefits constituted “other benefits” chargeable against the 70% net incremental proceeds under Section 5(2) of R.A. No. 6728. After receipt of the award, the unions sought an extension to file a petition for review, and the Court of Appeals (CA), by resolution dated July 2, 2008, granted an Urgent Motion for Extension. The unions filed a petition for review with the CA on July 16, 2008.
GNC moved to dismiss the petition before the CA, arguing that under Article 276 of the Labor Code (formerly Article 262-A) the voluntary arbitrator’s award became final and executory ten (10) days after receipt and was therefore unappealable; it relied principally on Coca‑Cola Bottlers Philippines, Inc. Sales Force Union‑PTGWO‑Balais v. Coca‑Cola Bottlers Philippines, Inc. (G.R. No. 155651, July 28, 2005). On December 15, 2008 the CA denied GNC’s Motion to Dismiss; the CA later denied reconsideration on January 30, 2009. GNC then filed a petition for certiorari with the Supreme Court, assailing th...(Pro-only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion in denying GNC’s Motion to Dismiss on the ground that the decision of the Voluntary Arbitrator had become final and executory under Article 276 of the...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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