Case Summary (G.R. No. 58870)
Applicable Law
The pertinent legal framework applies the 1987 Philippine Constitution and relevant labor legislation, particularly the Labor Code of the Philippines, including Presidential Decree No. 451 and B.P. Blg. 232 (The Education Act of 1982). These laws govern the rights of employees in relation to claims for money arising from employment relationships, stipulating time limits for filing claims.
Court's Initial Rulings
The Supreme Court addressed motions for reconsideration related to prior decisions issued on December 18, 1987, covering several issues not conclusively resolved in the original rulings. The Court reaffirmed that Section 42 of B.P. Blg. 232 effectively repealed previous law (Presidential Decree No. 451), clarifying the delegated power given to the Department of Education, Culture and Sports. The Court emphasized that this delegation complies with the constitutional standards against undue delegation of legislative power.
Prescription of Claims
In the Fabros case (G.R. No. 70832), the Court reiterated that claims related to money arising from the employer-employee relationship must be filed within three years as outlined under Article 292 of the Labor Code. The Court found that claims accruing before the three-year period would be barred by prescription, including those related to incremental proceeds from tuition fee increases mandated by law.
Negotiation Fees Clarification
In the Biscocho case (G.R. No. 76521), the Court sought to clarify the computation of the ten percent (10%) negotiation fees applicable to back wages. The Court ruled that this fee applies solely to the excess over the mandatory sixty percent (60%) allocation legally required for educational personnel, indicating that funds secured through bargaining need to be distinctly differentiated from those prescribed by law.
Claims Reassessment
The Court ruled on the Divine Word College of Legazpi case (G.R. No. 68345) concerning the computation base for claims made prior to the filing date. The ruling clarified that any claims before February 17, 1980, were considered prescribed and ordered a reassessment of actual incremental proceeds generated from the tuition fee increases in line with the established regulations.
Specific Cases Overview
For the Far Eastern University cases (G.R. Nos. 69224-25), it was determined that claims for the school year 1974-1975 were also prescribed, with the Court instructing the relevant parties on terms concerning the allocation of increments derived from tuition fees, particularly in the computation of the union's transportation allowance claim.
Attorney's Lien Issues
Motions regarding attorney's l
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Case Background
- This case involves a series of consolidated petitions concerning labor disputes related to the implementation of Pres. Dec. No. 451 and B.P. Blg. 232 regarding the sharing of incremental proceeds from tuition fee increases.
- The case encompasses multiple petitioners including Cebu Institute of Technology (CIT), Divine Word College of Legazpi, Far Eastern University Employees Labor Union, and various individual teachers and employees from different educational institutions.
- The main issue revolves around the interpretation and application of laws regarding money claims, particularly within the context of labor relations and education.
Key Legal Issues
- The primary legal questions include:
- Whether B.P. Blg. 232 repealed Pres. Dec. No. 451.
- The validity of the delegation of legislative power to the Department of Education, Culture and Sports (DECS).
- The applicability of the three-year period of prescription under the Labor Code to claims arising from tuition fee increases.
- The computation of negotiation fees and the definition of "backwages."
Fabros Case (G.R. No. 70832)
- Petitioners argue:
- Section 42 of B.P. Blg. 232 did not repeal section 3(a) of Pres. Dec. No. 451.
- There was undue delegation of legislative power to DECS.
- MECS Order No. 25, series of 1985, is an ultra vires act.
- Claims under Pres. Dec. No. 451 remain valid despite B.P. Blg. 232.
- The Court ruled:
- Section 42 of B.P. Blg. 232 effectively repealed Pres. Dec. No. 451.
- The stand