Case Summary (G.R. No. 139371)
Antecedents
- Under Section 5(2) of Republic Act No. 6728, 70% of any tuition fee increase must fund salaries, wages, allowances, and other benefits of teaching and non-teaching personnel.
- For school year 2006–2007, GNC imposed a 7% tuition increase and allocated part of the proceeds to its retirement plan, prompting the respondent unions to challenge the move as violative of R.A. 6728.
- The parties submitted the dispute to voluntary arbitration. On June 16, 2008, Arbiter Bacungan ruled in favor of GNC, holding that retirement benefits constitute “other benefits” chargeable against the 70% fund.
Procedural History
- Respondents received the arbitral decision on June 16, 2008, and sought a 15-day extension (until July 16) to file a petition for review with the CA. The CA granted the extension on July 2, 2008.
- On July 16, 2008, respondents filed a petition for certiorari and prohibition under Rule 65, seeking review of the arbitral decision via Rule 43.
- GNC moved to dismiss, arguing that under Article 276 of the Labor Code (formerly Article 262-A) the award became final and executory after 10 calendar days, rendering any appeal untimely.
- On December 15, 2008, the CA denied the Motion to Dismiss. GNC’s motion for reconsideration was likewise denied on January 30, 2009.
- GNC petitioned the Supreme Court for certiorari, contending that the CA acted without or in excess of jurisdiction by entertaining the appeal beyond the 10-day period.
Issue
Did the Court of Appeals gravely abuse its discretion in denying GNC’s Motion to Dismiss on the ground that the voluntary arbitrator’s decision had become final and executory after 10 days under Article 276 of the Labor Code, thereby ousting the CA of appellate jurisdiction?
Applicable Law
• 1987 Philippine Constitution – procedural and substantive rights, including labor-friendly construction.
• Labor Code, Article 276 (formerly Article 262-A) – voluntary arbitration procedure; awards become final and executory after ten calendar days from receipt.
• Rules of Court, Rule 43, Section 4 – petition for review to the CA must be filed within 15 days from notice of judgment or award.
• Revised Procedural Guidelines in the Conduct of Voluntary Arbitration Proceedings, Rule VII, Section 7 – originally disallowed motions for reconsideration.
Legal Analysis
Evolution of Judicial Review in Voluntary Arbitration
- Historically, arbitral awards were final, unappealable and immediately executory, but the Supreme Court recognized judicial review via certiorari for questions of law, jurisdiction, or grave abuse of discretion.
- In 1995, Luzon Development Bank v. ALDB Employees established that awards of voluntary arbitrators are quasi-judicial and appealable to the CA under Rule 43 of the Rules of Court, adopting a 15-day reglementary period.
- Subsequent jurisprudence alternately applied 15-day (Rule 43) and 10-day (Labor Code) periods, creating confusion.
Clarification of Appeal Periods
- In Teng v. Pagahac (2010), the Court held that the 10-day period in Article 276 is intended for filing a motion for reconsideration of the arbitral award, promoting exhaustion of administrative remedies.
- Only after resolution of such motion may an aggrieved party appeal to the CA by petition for review under Rule 43 within 15 days of notice.
Grave Abuse Standard
- Certiorari addresses jurisdictional errors and grave abuse of discretion, not mere procedural or factual errors.
- The CA, faced with conflicting jurisprudence, applied the labor-favoring principle to resolve doubts in favor of the union
Case Syllabus (G.R. No. 139371)
Antecedents
- Republic Act No. 6728 (Government Assistance to Students and Teachers in Private Education Act) Section 5(2) grants private schools a tuition‐fee increase, 70% of which must be used for salaries, wages, allowances, and other benefits of teaching and non‐teaching personnel.
- For School Year 2006–2007, Guagua National Colleges (GNC) imposed a 7% tuition‐fee increase in accordance with R.A. 6728.
- GNC’s Board of Trustees allocated part of those incremental proceeds to fund its retirement program, drawing from the “other benefits” category under Section 5(2).
- The GNC Faculty and Labor Union and the GNC Non‐Teaching Maintenance Labor Union challenged this unilateral decision as violating Section 5(2) of R.A. 6728.
- Failing to reach a settlement, the parties submitted their dispute to voluntary arbitration before Voluntary Arbitrator Froilan M. Bacungan.
Decision of the Voluntary Arbitrator
- Date of decision: June 16, 2008.
- Held that retirement benefits constitute “other benefits” chargeable against the 70% net incremental proceeds under R.A. 6728 Section 5(2).
- Ruled in favor of GNC, upholding the tuition‐fee increase and the Board’s funding arrangement.
- Decision became final and executory under Article 276 of the Labor Code after ten (10) calendar days from receipt, unless a motion for reconsideration or petition for review is filed within that period.
Procedural History
- June 16, 2008: Respondent unions received the Voluntary Arbitrator’s decision.
- Respondents filed an Urgent Motion for Extension to file petition for review, requesting until July 16, 2008.
- July 2, 2008: Court of Appeals (CA) granted the Urgent Motion for Extension.
- July 16, 2008: Respondents filed their petition for review under Rule 43 of the Rules of Court.
- GNC