Case Summary (G.R. No. 209516)
Background
Angelina Villanueva, a lawyer and certified public accountant, began her tenure with UE in 1970 and opted to retire after 23 years in 1993. Post-retirement, she was appointed as College Secretary and then Associate Dean of the College of Law while also teaching as a part-time lecturer. Her part-time contracts contained terms that disqualified her from receiving regular faculty benefits, including retirement gratuity.
Facts of the Case
In 2005, upon her compulsory retirement at 65 as Associate Dean, Villanueva sought to compute her retirement based on her full-time faculty pay rate from her previous employment, arguing that it should reflect her role in the College of Law rather than the College of Business Administration where she had formerly served as a full-time faculty member. UE denied her differential retirement pay, citing their "One Retirement Policy," which dictates that retirement benefits be calculated based on whichever role provides greater benefits—faculty or administrative—at the rate prevailing during retirement.
Labor Arbiter Ruling
The Labor Arbiter ruled in favor of Villanueva, emphasizing that her teaching position should dictate her retirement pay. She ordered UE to pay the differential amount of PHP 1,016,610.84 and additional damages. The Arbiter maintained that Villanueva’s service in the College of Law warranted consideration under the university's retirement policy.
National Labor Relations Commission (NLRC) Ruling
The NLRC overturned the Arbiter's decision, asserting that after her retirement from the College of Business Administration, Villanueva's connection to the university was primarily through her administrative roles. The NLRC emphasized the contractual nature of her teaching in the College of Law and maintained that the computation based on the College of Business Administration reflected a greater benefit.
Court of Appeals Ruling
The Court of Appeals upheld the NLRC's stance, confirming that Villanueva’s retirement pay was correctly calculated per the practice of utilizing the current hourly rate of a faculty member from the College of Business Administration. The appellate court dismissed her claims that her position as a part-time lecturer necessitated inclusion in the retirement computation.
Issues Presented
The primary issue before the Supreme Court was whether the appellate court erred in affirming the NLRC’s dismissal of Villanueva's complaint.
Supreme Court Ruling
The Supreme Court dismissed Villanueva’s petition, citing procedural deficiencies in her approach by opting for certiorari when an ordinary appeal was available. Additionally, the Court r
...continue readingCase Syllabus (G.R. No. 209516)
Background of the Case
- The case involves a Petition for Certiorari filed by Angelina Villanueva against the Honorable Court of Appeals, National Labor Relations Commission (NLRC), University of the East (UE), and various members of UE's Board of Trustees.
- The petition contests the May 31, 2013 Decision and the August 30, 2013 Resolution of the Court of Appeals, which upheld the NLRC's ruling that denied Villanueva's claim for retirement differential pay.
- The central issue revolves around the computation of retirement benefits and whether UE committed grave abuse of discretion.
Antecedents
- Villanueva, a lawyer and certified public accountant, joined UE as a regular full-time faculty member in 1970, serving in the College of Business Administration.
- After 23 years, she optionally retired in 1993 but continued her tenure at UE as College Secretary and later as Associate Dean, while also teaching part-time in the College of Law.
- Her part-time contracts specified she was not entitled to benefits afforded to regular faculty members, including retirement gratuity, as per the Collective Bargaining Agreement (CBA).
- In 2005, upon reaching the compulsory retirement age, Villanueva requested her retirement benefits, computed at PHP 627,279.79 based on the hourly rate of PHP 224.51 for faculty in the College of Business Administration.
Claims for Differential Retirement Pay
- Villanueva contested the computed amount, arguing it should be based on the College of Law's hourly rate of PHP 532.35, which would amount to PHP 1,016,610.84 in retirement differential pay.
- UE denied her request, invoking Board Resolution No. 75-8-86, which outlines the computation of retirement benefits, stating t