Case Digest (G.R. No. 213730)
Facts:
- The case involves Guagua National Colleges (petitioner) and the Guagua National Colleges Faculty Labor Union and Guagua National Colleges Non-Teaching and Maintenance Labor Union (respondents).
- In 2010, Guagua National Colleges implemented a 15% tuition fee increase for the school year 2010-2011.
- The tuition fee increase resulted in net tuition fee incremental proceeds (TIP) of P4,579,923.00 after accounting for scholarships, dropouts, unpaid accounts, and contingencies.
- Following Section 5 (2) of Republic Act No. (RA) 6728, the college allocated 70% of the TIP (P3,205,946.00) towards various employee benefits, including a significant contribution to the retirement benefit fund.
- On September 21, 2010, the respondents demanded that the 70% TIP be allocated exclusively to employee salaries, citing Section 182 (b) of the 2010 Revised Manual of Regulations for Private Schools in Basic Education.
- The petitioner argued that RA 6728, not the 2010 Revised Manual, governed the allocation.
- The dispute led to a preventive mediation case filed by the respondents before the National Conciliation and Mediation Board (NCMB), which was subsequently submitted to voluntary arbitration.
- The Voluntary Arbitrator ruled in favor of the respondents, directing the petitioner to reallocate the TIP according to DECS Order No. 15 and the 2010 Revised Manual.
- The Court of Appeals (CA) affirmed this decision.
- The petitioner then sought review from the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, reversing and setting aside the Decision dated February 13, 2014, and the Resolution dated July 25, 2014, of the Court of Appeals.
- The Court ruled that Guagua National Colleges' allocation of a port...(Unlock)
Ratio:
- The Supreme Court's decision hinged on the interpretation of "other benefits" in Section 5 (2) of RA 6728.
- The Court emphasized that the term "other benefits" should not be narrowly construed as "wage-related benefits" as limited by DECS Order No. 15, series of 1992.
- The Court reiterated the principle that the letter of the law prevails over administrative regulations.
- It cited the case of Cebu Institute of Medi...continue reading
Case Digest (G.R. No. 213730)
Facts:
The case involves Guagua National Colleges (petitioner) and the Guagua National Colleges Faculty Labor Union and Guagua National Colleges Non-Teaching and Maintenance Labor Union (respondents). In 2010, Guagua National Colleges implemented a 15% tuition fee increase for the school year 2010-2011, resulting in net tuition fee incremental proceeds (TIP) of P4,579,923.00 after accounting for scholarships, dropouts, unpaid accounts, and contingencies. Following Section 5 (2) of Republic Act No. (RA) 6728, the college allocated 70% of the TIP (P3,205,946.00) towards various employee benefits, including a significant contribution to the retirement benefit fund. On September 21, 2010, the respondents demanded that the 70% TIP be allocated exclusively to employee salaries, citing Section 182 (b) of the 2010 Revised Manual of Regulations for Private Schools in Basic Education. The petitioner argued that RA 6728, not the 2010 Revised Manual, governed the allocation. The dispute led to a preventive mediation case filed by the respondents before the National Conciliation and Mediation Board (NCMB), which was subsequently submitted to voluntary arbitration. The Voluntary Arbitrator ruled in favor of the respondents, directing the petitioner to reallocate the TIP according t...