Pursuant to the principle of separation of powers, the executive, legislative and judicial departments should be left alone to discharge their respective duties as they see fit. It also dictates that each department cannot lawfully exercise powers which are, in their nature, essentially that of the two other departments. In this case, the questions that arose involved the judicial function of interpreting laws enacted by the legislature. Can the court go beyond what the legislature has laid down and say what the law should be? Can it look into the wisdom of the law? Or can it remedy every unjust situation that may arise from the application of a particular law?
This case involves a non-stock, non-profit Catholic educational institution (the School) and a legitimate labor organization representing all of the employees of the school except the faculty and consultants of the Graduate School, managerial employees and those who occupy confidential positions (Samahan). The Samahan has an existing collective bargaining agreement (CBA) with the School.
For the school year 2000-2001, the School increased its tuition fees for all its departments. And pursuant to their CBA with the Samahan, the School shall allocate solely and exclusively, 85 percent of the incremental proceeds from said increase for adjustments in the employee salaries and benefits.
In computing the incremental proceeds of said increase, the school deducted the decrease in the number of enrollees, the number of those exempt from paying the fees, like scholars, the number of dropouts who as such do not pay the whole fees, and the bad debts incurred by the school. Based on this computation, the incremental proceeds from the tuition fee increase for that school year was about P3.5 million less than the computation made by the Samahan which was solely based on the rate of the tuition fee increase without any deduction. So the Samahan refused to accept the School’s computation. Hence the parties resorted to voluntary arbitration.
After the parties were heard and their supporting documentary evidence presented, the Panel of Voluntary Arbitrators ruled in favor of the Samahan. So the School appealed to the Court of Appeals (CA) which, in effect still ruled in favor of the Samahan. The CA cited Section 5, of Republic Act 6728 which states that the incremental proceeds should be determined simply from the additional fees charged over the students times the number of students regardless of the gross income and of the number of enrollees for the period in question.
The School thus appealed to the Supreme Court arguing that the incremental proceeds should be determined on the basis of the School’s income not merely on the categorical increase in the tuition fee as determined by the CA. And if the present year’s income is less than that of the previous year due to a lesser number of current enrollees, then there may be no gain or “incremental proceeds but a loss or decreased proceeds. In other words the School contended that it is the net increase in tuition fee income and not the rate or amount of increase in tuition fees charged that enables the School to distribute increase in salaries and benefits of the employees. According to the school, the CA’s formula actually oppresses the school’s interest because it would require them to pay increases in employee compensation despite a loss in tuition income which may eventually lead to their closure.
The SC however ruled that it sympathizes with the dilemma of the School and even on other educational institutions similarly situated in their desire to raise teacher compensation and expand school facilities by resorting to painful increases in tuition fees, only to find out later that – despite their good intentions – their gross revenues actually decreases because of the less number of enrollees who cannot afford the increases. But it could not go beyond what the legislature has laid down which plainly states that only a certain percentage of the tuition fee increase shall be allotted for the teaching and non-teaching personnel. It should not be based on other factors like decrease in the number of enrollees, in the number of those exempt in paying the fees like scholars, in the number of dropouts who do not pay the whole fees, and the bad debts of the school. The Court Judiciary could not go beyond what the legislature has laid down, or what the law should be, to remedy the unjust situation. The remedy lies not in the Court but in Congress. Besides, the School failed to present evidence that it suffered bottom line losses as direct and necessary consequence of the tuition fee increase. Its averments are mere conjectures sorely insufficient to overturn the CA judgment (St Joseph’s College vs. St. Joseph’s Workers Association (Samahan), G.R. 155609, January 17, 2005).
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