Case Digest (G.R. No. L-70308) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In International School Alliance of Educators (ISAE) v. Quisumbing, G.R. No. 128845, decided on June 1, 2000 under the 1987 Constitution, petitioner ISAE, the certified union of faculty members of International School, Inc., challenged the School’s practice of classifying its educators into “foreign-hires” and “local-hires” and paying the former a 25% higher salary as well as housing, transportation, shipping costs, tax relief, and home-leave allowances. The School, organized under Presidential Decree No. 732 to serve dependents of diplomatic personnel and temporary residents, applied a four-factor “point-of-hire classification” (domicile, home economy, economic allegiance, and point of recruitment) to distinguish foreign-hires, who are recruited abroad on limited tenure, from local-hires, mostly Filipino, who enjoy security of tenure. During collective bargaining negotiations in June 1995, ISAE protested the salary differential and the exclusion of foreign-hires from the bargai Case Digest (G.R. No. L-70308) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature and Authority of the School
- International School, Inc. (the School) is a domestic educational institution established under Presidential Decree No. 732 to serve dependents of foreign diplomatic personnel and temporary residents.
- Section 2(c) of PD 732 authorizes the School to employ teaching and management personnel locally or abroad, exempt from general labor regulations except laws enacted for employee protection.
- Classification and Compensation of Faculty
- The School classifies faculty into “foreign-hires” and “local-hires” based on four point-of-hire tests: domicile, home economy, economic allegiance, and whether hired abroad and brought to the Philippines.
- Foreign-hires receive a 25% higher salary plus housing, transportation, shipping, tax coverage, and home-leave allowances, justified by the School as compensation for “dislocation” and “limited tenure.”
- Collective Bargaining Dispute
- In June 1995, the International School Alliance of Educators (ISAE), representing all faculty, challenged the salary differential and sought inclusion of foreign-hires in the bargaining unit. A strike notice was filed on September 7, 1995.
- The DOLE Acting Secretary issued an order (June 10, 1996) upholding the School’s classification; the Labor Secretary denied reconsideration (March 19, 1997). ISAE elevated the matter to the Supreme Court.
Issues:
- Whether the point-of-hire classification justifying a 25% salary differential between foreign-hires and local-hires violates the principle of equal pay for equal work and public policy against discrimination.
- Whether foreign-hires should be included in the same collective bargaining unit as local-hires.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)