Government Service Insurance System v. Government Service Insurance System Supervisors Union
REITERATIONFacts
The Antecedents: The Government Service Insurance System (GSIS) implemented a new pay scale on January 1, 1968, adjusting salaries. It was discovered that some employees, particularly those in Pay Classes 7 to 13, including acting designees, received higher salary readjustments than others. Rank-and-file employees (Pay Classes 1-6) also received similar adjustments. Members of the GSIS Supervisors Union (GSISSU) and the GSIS Employers Association (GSISEA-PAGE) did not receive these benefits, leading to agitation and a perception of discrimination. Procedural History: On March 19, 1970, GSISSU requested a one-rate salary increase for all GSIS employees. The GSIS Personnel Manager also recommended extending the benefits. When no immediate action was taken, GSISSU and GSISEA-PAGE filed petitions with the Court of Industrial Relations (CIR) on March 19 and 20, 1970, respectively, alleging discrimination and bypass of union members in pay promotions. The GSIS opposed, citing Board Resolution No. 1461. GSISEA-CUGCO intervened, claiming the increases given to some of its members were part of a collective bargaining agreement and praying for similar benefits for its members. The CIR issued an Order on April 29, 1970, in IPA Case No. 87(8) (GSISSU vs. GSIS), ordering the GSIS to cease discriminating and grant the same salary readjustment to supervisors. The GSIS filed a motion for reconsideration, which was denied by the CIR en banc for being filed out of time. In IPA Case No. 87(9) (GSISEA-PAGE vs. GSIS), the CIR issued an Order on June 10, 1970, directing the GSIS to grant rank-and-file employees the same salary readjustment and to deduct attorney's fees. The GSIS filed a motion for reconsideration, which was also denied. The GSIS filed petitions for review by certiorari in both cases. The Petition: The GSIS filed petitions for review by certiorari, assigning as errors the CIR's grave abuse of discretion in issuing the orders, holding the GSIS financially capable without sufficient evidence, and awarding indiscriminate salary adjustments disregarding the merit system and fund availability.
Issue(s)
Whether the Motion for Reconsideration in IPA Case No. 87(8) was filed on time and if the underlying Order became final. Whether the Court of Industrial Relations (CIR) committed grave abuse of discretion in finding the GSIS financially capable of meeting the salary adjustments. Whether the award of a one-step salary adjustment was improper for disregarding the merit system.
Ruling
In G.R. No. L-32018, the petition is dismissed, and the Order of the Court of Industrial Relations of April 29, 1970, is declared final and executory. In G.R. No. L-32397, the Order of the Court of Industrial Relations of June 10, 1970, is affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Motion for Reconsideration was filed beyond the reglementary period. Under Section 17-A of the Rules of the Court of Industrial Relations, a party has four days from receipt of an order to file a motion for reconsideration. This four-day period is mandatory and jurisdictional. The GSIS received the order on April 30, 1970, making May 4 the deadline; however, the motion was filed on May 5. The excuses provided by the Assistant Government Corporate Counsel—attending a hearing in Baguio and suffering leg burns—do not constitute excusable negligence. The Court emphasized that government legal offices must have adequate measures to ensure court processes are attended to even in the absence of the specific attorney assigned to a case. Applying the ruling in NWSA v. MWSA Supervisors Union, the failure of a lawyer to file on time due to illness is not excusable when the office handles public funds and requires an exacting sense of responsibility. On Issue 2: The Court found no merit in the claim that the CIR lacked evidence of financial capability. The CIR based its conclusion on a Consolidated Statement of Financial Condition and the testimony of the GSIS Assistant General Manager for Accounting. The evidence showed that the GSIS was expected to realize a net income of approximately P49,995,000.00 available for dividends and contingencies, easily covering the P4,049,134.00 required for the salary adjustments. The Court held that as long as there is evidence to support a decision of the CIR, it may not be revoked just because it is not based on overwhelming or a preponderance of evidence. Factual findings of administrative bodies, when supported by substantial evidence, are generally accorded great respect by the judiciary. On Issue 3: The Court rejected the argument that the award disregarded the merit system. It clarified that the merit system was not the central point of the litigation; rather, the CIR sought to remedy the 'discriminatory effect' of the GSIS's own actions. The GSIS had unilaterally granted salary increases to certain members of one union while bypassing others in the same bargaining unit. By granting the same benefit to all similarly situated employees, the CIR was merely correcting an unfair labor practice. The only condition relevant to the adjustment was that the employees had not yet reached the maximum step of their pay classes, which was a condition previously utilized by the GSIS General Manager himself.
Main Doctrine
The 4-day period for filing a motion for reconsideration under Section 17-A of the Rules of the Court of Industrial Relations is jurisdictional and mandatory. Failure to comply therewith is fatal. Reasons advanced for late filing, such as illness of counsel or his clerk, or being out of town for hearings, without adequate measures taken by the office to ensure timely filing, do not constitute excusable negligence.