Case Digest (G.R. No. 82312)
Facts:
Manuel L. Quezon University Association et al. v. Manuel L. Quezon Educational Institution, Inc., Hon. Dionisio C. Dela Serna, G.R. No. 82312, April 19, 1989, First Division, Grino‑Aquino, J., writing for the Court.On April 24, 1979, petitioners—faculty members of Manuel L. Quezon University (MLQU) represented by the MLQ University Faculty Association and several named teachers—filed a complaint with the Regional Director, DOLE Region IV, for unpaid salary differentials allegedly due under Presidential Decree No. 451 (P.D. 451), which authorized tuition increases with the requirement that 60% of the increment be used to raise school employees’ salaries. The Bureau of Higher Education had authorized a 15% tuition increase for the school years 1974–1975, 1975–1976 and 1977–1978; petitioners claimed the University paid only P0.50 per lecture hour instead of the higher amounts they computed (Annexes C & D).
On October 22, 1979, twenty‑five of the complainants filed a motion to withdraw from the case. On January 25, 1980, the MLQU Teachers and Allied Workers Union (NATAW) intervened. Director Severino M. Pucan (DOLE Region IV) issued an order on June 15, 1983 (docketed LRC Case No. RX FSO‑4‑541‑79) upholding the claims in part, but declaring claims accruing before April 24, 1976 (and for intervenors before January 25, 1977) prescribed; he directed payment of specified differentials and dismissed the claims of the twenty‑five who withdrew as moot.
Petitioners received the June 15, 1983 order on June 22, 1983 and filed a motion for reconsideration on July 25, 1983, which was treated as an appeal. On December 12, 1984, Deputy Minister Leogardo dismissed the appeal as filed beyond the ten‑day reglementary period under Article 223 of the Labor Code, declaring Director Pucan’s order final and unappealable. Petitioners sought reconsideration; on December 6, 1985 Deputy Minister Leogardo reversed course, reinstated the appeal and substantially increased the awarded differentials (ordering aggregate differentials of P3.26 and P4.91 per hour for specified periods). Both parties filed motions for reconsideration of that December 6, 1985 order.
On November 18, 1987 Undersecretary Dionisio C. Dela Serna of the DOLE annulled Deputy Minister Leogardo’s December 6, 1985 order on the ground that petitioners’ motion for reconsideration/appeal from Director Pucan’s June 15, 1983 order was filed late, thereby rendering that order final; Leogardo therefore lacked jurisdiction to entertain the late appeal. A motion for reconsideration of the Undersecretary’s order was denied on February 17, 1988. Petitioners then filed this petition for certiorari in the Supreme Court, alleging grave abuse of discretion in: (1) declaring their appeal filed out of time; (2) annulling Leo...(Pro-only)
Issues:
- Did the Undersecretary gravely abuse his discretion in declaring petitioners’ appeal from Director Pucan’s June 15, 1983 order to be filed out of time (i.e., was the ten‑day appeal period under Article 223 of the Labor Code computed in working days or calendar days)?
- Did the Undersecretary gravely abuse his discretion in annulling Deputy Minister Leogardo’s December 6, 1985 order that reinstated the appeal and increased the pay differentials?
- Did petitioners’ claims for salary differentials for the school years 1974–1975 and 1975–1976 prescribe despite their written extrajudicial demand and the University’s reply?
- Was the exclusion of the twenty‑five faculty members from the benef...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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