Case Summary (G.R. No. 82312)
Petition Background and Initial Complaints
On April 24, 1979, the petitioners filed a complaint with the Department of Labor and Employment (DOLE) regarding unpaid salary differentials, arguing that the university did not properly allocate the tuition increases mandated by P.D. No. 451. Under this decree, the university was permitted to raise tuition fees by 15% for certain school years, with the stipulation that 60% of this increase should directly benefit salaries of faculty and non-faculty employees. The petitioners contended they received minimal increases, far below the required amounts.
Filing and Dismissal of Claims
During the proceedings, certain complainants withdrew from the case due to lack of interest, and the MLQU Teachers and Allied Workers Union intervened to support the remaining claims. In a June 15, 1983 order, the Regional Director upheld the claims for salary differentials; however, it also noted that those claims accrual based on timelines extending beyond three years prior to the filing of the complaint were already prescribed. The director subsequently directed the university to compensate for the unprescribed amounts, indicating a complex interplay between the alleged salary differentials and the prescribed period for filing complaints.
Motions for Reconsideration and Appeal Dismissals
After the petitioners received the June 15, 1983 order, they filed a motion for reconsideration, which was later treated as an appeal. This appeal was dismissed on December 12, 1984, due to being filed beyond the ten-day appeal period outlined in Article 223 of the Labor Code. An unexpected reversal occurred when a year later, Deputy Minister Leogardo reinstated the appeal and increased the awarded salary differentials, reflecting the fluctuating interpretations of compliance with labor regulations.
Challenges to the Undersecretary's Orders
The petitioners contested Undersecretary Dela Serna's orders from November 1987 and February 1988, which annulled Deputy Minister Leogardo’s increasing award of pay differentials, claiming that the appeal was improperly assessed as late, asserting grievances related to the duration of their claims, and objecting to the exclusion of the faculty members who had dropped out of the case.
Court's Ruling on Timeliness and Prescription
The court ultimately dismissed the petition for lack of merit. It confirmed that the petitioners' appeal was indeed filed late, as their timeline for appeal calculation was incorrectly interpreted. The determination emphasized that the ten-day period referred to calendar days and that claims for salary differentials from before April 24, 1976, had already prescribed, aligning with previous jurisprudence regarding employer-employee financial disputes.
Interpretation of Prescription and Exclusion Argument
The ruling further delineated that while the petitioners argued interruptions in the pr
...continue readingCase Syllabus (G.R. No. 82312)
Case Overview
- This case involves a petition for certiorari filed by the MLQ University Faculty Association and several faculty members against the Manuel L. Quezon Educational Institution (MLQ University) and Undersecretary of Labor and Employment Dionisio C. Dela Serna.
- The petition seeks a review of the Orders dated November 18, 1987, and February 17, 1988, concerning the complaint for unpaid salary differentials lodged by the petitioners against the University.
Background of the Case
- On April 24, 1979, the petitioners filed a complaint against MLQ University for unpaid salary differentials, referencing P.D. No. 451, which mandated the allocation of a portion of tuition fee increases to faculty salaries.
- The Bureau of Higher Education had authorized MLQ University to increase tuition fees by 15% for several school years, with the stipulation that 60% of this increase should be used to augment salaries for faculty and non-faculty employees.
- The petitioners claimed that the University only granted them a meager increase of P0.50 per lecture hour instead of the mandated P2.11 and P2.15 for the respective school years.
Proceedings Before the Department of Labor and Employment
- The initial complaint was registered as LRC Case No. RX FSO-4-541-79.
- A significant number of complainants dropped out of the case in 1979, citing a lack of