Cebu Institute of Medicine v. Cebu Institute of Medicine Employees' Union-National Federation of Labor
NEW DOCTRINEFacts
The Antecedents: The Cebu Institute of Medicine (CIM), a non-stock, non-profit educational institution, was charging the employer's mandatory share in SSS, Medicare, and Pag-Ibig premiums against the seventy percent (70%) incremental tuition fee increase authorized under Sec. 5, par. (2), of RA 6728. The Cebu Institute of Medicine Employees' Union – National Federation of Labor (UNION) asked CIM to stop this practice. Procedural History: The dispute was submitted to voluntary arbitration. The Voluntary Arbitrator ruled in favor of the UNION, holding that charging the employer's share against the seventy percent (70%) incremental tuition fee increase contravened Sec. 19 of RA 1161 and ordered CIM to refund the premiums and refrain from the practice. CIM appealed to the Court of Appeals, arguing that the Voluntary Arbitrator erred in disregarding Sec. 5, par. (2), of RA 6728. The Court of Appeals affirmed the Voluntary Arbitrator's ruling. The Petition: CIM filed a petition with the Supreme Court, seeking to reverse the decision of the Court of Appeals.
Issue(s)
Whether the mandatory share of an educational institution in SSS, Medicare, and Pag-Ibig premiums may be charged against the seventy percent (70%) incremental tuition fee increase authorized under Section 5, par. (2), of Republic Act No. 6728.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. Petitioner Cebu Institute of Medicine (CIM) is allowed to charge its share in the SSS, Medicare and Pag-Ibig premiums against the seventy percent (70%) incremental tuition fee increase under Sec. 5, par. (2) RA 6728.
Ratio Decidendi
On Issue 1: The Supreme Court reasoned that Section 5, par. (2) of Republic Act No. 6728 (RA 6728) explicitly mandates that 70% of the tuition fee increase be allotted for 'salaries, wages, allowances and other benefits.' The Court found that SSS, Medicare, and Pag-Ibig premiums naturally fall under the category of 'other benefits' because they are for the ultimate benefit of the teaching and non-teaching personnel. Applying the legal maxim 'ubi lex non distinguit, nec nos distinguere debemus,' the Court held that since the law does not provide a specific prohibition against charging the employer's share to this fund, the courts should not create such a distinction. The Court observed that the employer's share is integrated into the benefit package; therefore, the educational institution possesses the discretion to determine how to dispose of the 70% fund, provided the entire amount goes to the employees' welfare. Furthermore, the Court pointed out that under the predecessor laws like Batas Pambansa Blg. 232 (BP Blg. 232), specifically in the case of University of Pangasinan v. Confesor, social security and medicare contributions were already recognized as valid charges against the incremental tuition fee increase. Finally, the Court noted that the remaining 30% of the increase is strictly reserved by law for the improvement of facilities and costs of operation, leaving no other source for the employer's share if it were not taken from the 70% allocation.
Main Doctrine
The employer's mandatory share in SSS, Medicare, and Pag-Ibig premiums may be charged against the seventy percent (70%) incremental tuition fee increase authorized under Section 5, par. (2) of RA 6728, as these contributions fall under the category of "other benefits" for teaching and non-teaching personnel.