Case Digest (G.R. No. 90445)
Facts:
Ust Faculty Union v. National Labor Relations Commission and University of Santo Tomas, Inc., G.R. No. 90445. October 02, 1990. Supreme Court En Banc. Cortes, J., writing for the Court.Petitioner UST Faculty Union represented the faculty of the University of Santo Tomas, Inc. (UST); respondents were the National Labor Relations Commission (NLRC) and UST. The dispute arose from a March 25, 1985 compromise agreement between UST and the Union settling the faculty’s share of tuition-fee increases under Presidential Decree No. 451. The agreement fixed an aggregate benefit of P35,000,000 to be distributed over three school years (1985–1988) and specifically provided a “Christmas gift” of P2,000 for full-time and P1,000 for part-time faculty for School Year 1985–1986 (with similar benefits for subsequent years).
Before 1986 UST did not pay a statutory 13th month pay because under Presidential Decree No. 851 the requirement initially applied only to employees receiving a basic salary of not more than P1,000. On August 13, 1986, Memorandum Order No. 28 modified PD 851 to require payment of the 13th month pay to all rank-and-file employees; consequently UST became subject to the 13th month pay requirement beginning 1986. Faculty members feared UST would treat the March 25, 1985 Christmas gift as credit toward the newly applicable 13th month pay.
In December 1986 faculty leaders corresponded with the rector; UST’s legal counsel advised that the Christmas gift could be credited as compliance with the 13th month pay. The Union disagreed and, after internal grievance proceedings produced a unanimous Grievance Adjudication Committee decision (March 27, 1987) holding that the P2,000/P1,000 was part of the P35M settlement and not creditable as a 13th month bonus, UST nonetheless refused to accept that ruling. The Union filed an arbitration complaint with the Labor Arbiter on December 10, 1986 seeking to compel UST not to deduct the Christmas gift from the 13th month pay.
On January 4, 1989 the Labor Arbiter dismissed the Union’s complaint, holding that the Christmas gift could be considered an equivalent of the 13th month pay under the rules implementing PD 851. The NLRC, on appeal, affirmed the dismissal in a decision...(Pro-only)
Issues:
- Did the NLRC gravely abuse its discretion in affirming the Labor Arbiter’s dismissal of the Union’s complaint?
- Can the P2,000/P1,000 “Christmas gift” under the March 25, 1985 agreement be credited as an equivalent of the 13th month pay under P.D. No. 851, as amended by Memorandum Order No. 28, and the Rule...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)