Manuel L. Quezon University Association v. Manuel L. Quezon Educational Institution, Inc.
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns claims by faculty members of Manuel L. Quezon University (MLQU) for unpaid salary differentials. These claims arose from a tuition fee increase authorized by P.D. No. 451, which mandated that 60% of the increment be used for salary increases of faculty and non-faculty employees. The faculty alleged that MLQU failed to disburse the full amount due to them, providing only a minimal increase per lecture hour instead of the mandated amounts for the school years 1974-1975, 1975-1976, and 1977-1978. 2. Procedural History: The faculty members filed a complaint with the DOLE Regional Director on April 24, 1979. After some complainants withdrew and a union intervened, the Regional Director issued an order on June 15, 1983, granting part of the salary differentials but dismissing claims that had prescribed. The faculty's motion for reconsideration was treated as an appeal, which was initially dismissed by the Deputy Minister of Labor on December 12, 1984, for being filed out of time. However, on December 6, 1985, the Deputy Minister reinstated the appeal and modified the award, increasing the pay differentials. Both parties moved for reconsideration. Subsequently, on November 18, 1987, the Undersecretary of Labor and Employment annulled the Deputy Minister's order, ruling that the original appeal was indeed filed late and the Regional Director's order had become final. The Undersecretary's denial of the faculty's motion for reconsideration on February 17, 1988, led to the present petition. 3. The Petition: The petitioners, the MLQ University Faculty Association and named teachers, filed this petition for certiorari under Rule 45 of the Rules of Court, seeking to annul the Undersecretary's Orders of November 18, 1987, and February 17, 1988. They argue that the Undersecretary gravely abused his discretion by incorrectly declaring their appeal out of time, annulling the Deputy Minister's order that increased their pay differentials, holding that their claims for certain school years had prescribed despite written demands and acknowledgments, and excluding twenty-five faculty members who were similarly situated.
Issue(s)
Whether the appeal from the Regional Director's Order was filed within the reglementary period. Whether the Undersecretary gravely abused his discretion in annulling the Deputy Minister's Order. Whether the petitioners' claims for pay differentials for the school years 1974-1975 and 1975-1976 had prescribed. Whether the exclusion of twenty-five faculty members from the benefits constituted discrimination.
Ruling
The petition is dismissed for lack of merit. The Supreme Court affirmed the Undersecretary's ruling that the appeal was filed out of time, that the claims for differentials prior to April 24, 1976, had prescribed, and that the exclusion of the twenty-five faculty members was justified.
Ratio Decidendi
On the timeliness of the appeal: The Court held that the ten-day appeal period under Article 223 of the Labor Code contemplates calendar days, not working days, citing previous jurisprudence. Petitioners received the Regional Director's Order on June 22, 1983. The ten-day period expired on July 2, 1983. Their motion for extension was filed six days late, and their motion for reconsideration/appeal was filed 33 days late. Therefore, the Regional Director's Order had become final and unappealable. On the annulment of the Deputy Minister's Order: Since the petitioners' motion for partial reconsideration of the Regional Director's Order was filed late, that order became final and unappealable. Consequently, the Deputy Minister had no jurisdiction to entertain their late appeal and his subsequent order modifying the award was a nullity. The Undersecretary correctly annulled this order. On the prescription of claims: The Court reiterated that the three-year prescriptive period under Article 292 of the Labor Code applies to money claims arising from employer-employee relations, including claims for incremental proceeds from tuition fees under P.D. 451. The petitioners' claims accruing prior to April 24, 1976, were filed on April 24, 1979, which was more than three years after the cause of action accrued. The written demand made on November 4, 1974, and the University president's reply on the same date, only interrupted prescription until November 4, 1977. The subsequent complaint to President Marcos was not a filing before the court or a written acknowledgment by the debtor as required by Article 1155 of the Civil Code. Thus, the claims had prescribed. On the exclusion of twenty-five faculty members: The Court found no discrimination in excluding the twenty-five faculty members who had voluntarily filed a motion to dismiss, explicitly stating their lack of interest in pursuing the case. Their exclusion was in accordance with their own prayer and did not constitute an abuse of discretion.
Main Doctrine
The ten-day appeal period under Article 223 of the Labor Code contemplates calendar days, not working days. Claims for money arising from employer-employee relations are governed by the three-year prescriptive period under Article 292 of the Labor Code, which is a special law, not the ten-year period under the Civil Code, a general law. Written extrajudicial demands and acknowledgments of debt interrupt prescription only if made in accordance with Article 1155 of the Civil Code.