University of the Philippines v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The University of the Philippines Employees' Welfare Association (UPEWA) and Tomas C. Tolibas filed a complaint for unfair labor practice against the University of the Philippines, the U. P. College of Agriculture, and Prof. Dioscoro L. Umali. The complaint alleged that Umali interfered with employees' right to self-organization and that respondents conspired to refuse Tolibas' reappointment, separating him from service, constituting unfair labor practice under Republic Act No. 875. Procedural History: The Court of Industrial Relations (CIR), after investigation and hearing, ordered the reinstatement of Tomas C. Tolibas with back pay and enjoined respondents from discouraging union affiliation. Respondents moved for reconsideration, raising issues of jurisdiction (government instrumentality, no industrial dispute) and factual findings. The CIR en banc denied the motion. Respondents filed a petition for review. The Petition: Petitioners (University of the Philippines, et al.) seek to set aside the CIR's order, primarily arguing that the CIR has no jurisdiction over a government instrumentality and that Tolibas' separation was justified due to his temporary employment status and fund reductions.
Issue(s)
Whether the Court of Industrial Relations erred in ordering the reinstatement of a temporary employee whose non-reappointment was necessitated by a reduction in project funding.
Ruling
The petition is granted. The order of the Court of Industrial Relations is set aside.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the university authorities were justified in terminating Tolibas's employment because he was a temporary employee whose funding had been discontinued. The Court emphasized that a temporary appointment does not grant a fixed tenure of office, making the employment dependent on the pleasure of the appointing power. Applying the ruling in Mendez v. Ganzon, the Court held that a temporary appointment is akin to an acting capacity and can be terminated at a moment's notice without the need to show cause. The evidence showed that the Cornell allotment, which funded Tolibas's position, was reduced from P23,000 to P18,000, requiring the layoff of four laborers. Furthermore, the Court noted that of the four laborers separated, three were non-union members, while other union members were retained, which refuted the allegation of discriminatory discharge based on union activity. Following the doctrine in Villanosa v. Alera, the Court reiterated that the nature of the appointment extended determines the tenure, not the nature of the item filled. Therefore, Tolibas's sudden non-reappointment was a valid exercise of administrative discretion due to the temporary nature of his contract and the financial constraints of the project.
Main Doctrine
The Court of Industrial Relations lacks jurisdiction over labor disputes involving government instrumentalities. Furthermore, temporary employees, whose appointments are for a fixed term and terminable at pleasure, do not possess a fixed tenure of office and their employment may be terminated without the need to show cause, especially when funds for their positions are discontinued.