Case Summary (G.R. No. 171351)
Relevant Legal Framework
The pertinent law governing this case includes Republic Act No. 6758, known as the Salary Standardization Law, enacted on July 1, 1989, which aimed to consolidate allowances into standardized salaries for government employees. The backdrop includes the controversial DBM Circular No. 10, which declared the discontinuation of various allowances without prior publication, leading to legal challenges regarding the rights of government employees.
Background Facts
MWSS is a government-owned entity created under Republic Act No. 6234, while the respondents are its employees, both current and former. Before November 1, 1989, the employees received COLA, benefits, and allowances equivalent to 40% of their basic monthly salary. However, following the enactment of RA 6758 and the issuance of DBM Circular No. 10, these benefits were suspended, leading to a dispute regarding the employees’ entitlement to the COLA.
Initial Dispute and Lower Court Proceedings
In response to MWSS’s payment of only 5% of the claimed COLA, the respondents sought the remaining 95% through mandamus, asserting their legal entitlement. The Regional Trial Court (RTC) of Quezon City ruled in favor of the respondents, ordering MWSS to pay the outstanding COLA due to the ineffectiveness of DBM Circular No. 10 resulting from its lack of publication, thereby recognizing the respondents’ claims to the allowance.
Court of Appeals Ruling
The Court of Appeals upheld the RTC decision with modifications. It affirmed the legal basis for the respondents' entitlement to COLA from 1989 to 1999, maintaining that mandamus was an appropriate remedy to compel MWSS's compliance with its obligation to pay. However, it adjusted the terms of litigation expenses, reducing the awarded amount to a fixed fee rather than a percentage of claims.
Supreme Court's Final Decision
The Supreme Court concurred with the lower courts, confirming that the respondents were entitled to COLA for the stated period, clarifying that the DBM Circular's failure to be properly published rendered it ineffective. The Court recognized MWSS’s ministerial duty to process and deliver the required payments without further obstacles, firmly establishing that employees entitled to bene
...continue readingCase Syllabus (G.R. No. 171351)
Case Background
- This case is a sequel to previous cases involving the refusal of a government-owned and controlled corporation to pay its employees their Cost of Living Allowance (COLA) from 1989 to 1999.
- Petitioner Metropolitan Waterworks and Sewerage System (MWSS) filed a petition for review on certiorari against private respondents, who are incumbent and former employees of MWSS.
Legal Framework
- MWSS is organized under Republic Act (R.A.) No. 6234.
- Prior to November 1, 1989, private respondents received COLA, which constituted 40% of their basic monthly salary or a minimum of P300.00 per month.
- The discontinuation of these benefits was mandated by R.A. No. 6758, known as the Salary Standardization Law, which was implemented by DBM Circular No. 10.
Key Legal Developments
- The Supreme Court, in the case of De Jesus v. Commission on Audit, declared DBM Circular No. 10 ineffective due to a lack of publication.
- The Office of the Government Corporate Counsel (OGCC) later opined that all employees of government-owned corporations were entitled to COLA during the period it was suspended.
MWSS Actions
- In 2003, MWSS issued a Board Resolution granting only a 5% COLA to employees for the period from November 1989 to July