Case Digest (G.R. No. 156225)
Case Digest (G.R. No. 156225)
Facts:
Letran Calamba Faculty and Employees Association v. National Labor Relations Commission and Colegio de San Juan de Letran Calamba, Inc., G.R. No. 156225, January 29, 2008, the Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.Petitioner Letran Calamba Faculty and Employees Association (the Union) filed a money-claims complaint on October 8, 1992 with Regional Arbitration Branch No. IV of the National Labor Relations Commission (NLRC) against private respondent Colegio de San Juan de Letran, Calamba, Inc. (the School) alleging several unpaid monetary claims (inclusion of overload in 13th‑month pay, unpaid wage increases under Wage Order No. 5, erroneous computation of overload compensation per unit, unpaid job-grading increases for non‑academic personnel, unpaid shares in tuition fee increases, and unpaid holiday pay). The complaint was docketed as NLRC Case No. RAB-IV-10-4560-92-L.
The School answered; the Union filed a reply. Prior to resolution, the Union had also filed a separate money-claims complaint with DOLE Regional Office No. IV (later docketed NLRC Case No. RAB-IV-11-4624-92-L). While the main NLRC matter was pending, the School filed a petition with the NLRC declaring illegal a strike staged by petitioner in January 1994 (docketed NLRC Case No. RAB-IV-3-6555-94-L). The three matters were consolidated for disposition by the Labor Arbiter (LA).
On September 28, 1998 the LA dismissed the two money-claims cases for lack of merit and likewise dismissed the School’s petition to declare the strike illegal, although the LA reprimanded the Union officers. Both parties appealed to the NLRC, which on July 28, 1999 affirmed the LA by dismissing the appeals; the NLRC denied reconsideration on June 21, 2000. The Union then filed a special civil action for certiorari with the Court of Appeals (CA), which dismissed the petition on May 14, 2002 and denied reconsideration on November 28, 2002.
Petitioner thereafter brought this Petition for Review on Certiorari under Rule 45, assigning errors that (1) the CA erred in holding factual findings of the NLRC cannot be reviewed in certiorari; (2) the CA refused to rule whether faculty overload pay should be included in the 13th‑month computation; and (3) the CA erred in finding the NLRC’s decision supported by substantial evidence and in not granting petitioner’s monetary claims. The petition invoked conflicting DOLE interpretations (the Bureau of Working Conditions’ opinions and DOLE explanatory bulletin favoring inclusion; the DOLE Legal Services opinion and the DOLE‑DECS‑CHED‑TESDA Order No. 02, Series of 1996 favoring exclusion) and argued retroactive application of the 1996 DOLE Order would deprive vested benefits.
Issues:
- In a Rule 45 petition, may the Court of Appeals or the Supreme Court review and reverse the NLRC’s factual findings in the absence of a showing of grave abuse of discretion or lack of jurisdiction?
- Should a teacher’s pay for overloads be included as part of basic salary for computation of the 13th‑month pay?
- Are the NLRC’s factual findings and conclusions denying the Union’s various monetary claims supported by substantial evidence so as to preclude relief on certiorari?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)