JRC V NLRC

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JOSE RIZAL COLLEGE V.

NLRC
G.R. No. L-65482
December 1, 1987
FACTS. The Jose Rizal College, the petitioner filed for a re-examination regarding the decision
of the National Labor Relations Commission in favor of the National Alliance of Teachers and
Workers on the appeal to make the Jose Rizal College pay their contractual professors non-
working holiday pay.
The petitioner has three classes of employment, each with their corresponding pay. These are the
following, lifted directly from G.R. No. L-65482:
“a) personnel on monthly basis, who receive their monthly salary uniformly
throughout the year, irrespective of the actual number of working days in a month without
deduction for holidays;
(b) personnel on daily basis who are paid on actual days worked and they receive
unworked holiday pay; and
(c) collegiate faculty who are paid on the basis of student contract hour.”
The National Alliance of Teachers and Workers, one of the respondents, and the JRC could not
reach an agreement, and their case was recommended to the National Labor Relations
Commission, the other respondent. The judgment rendered by the arbiter was to assume that the
first two classes of workers were already being paid the required holiday pay, and that the
collegiate faculty were not. As such, the NLRC ruled that the faculty be given non-working holiday
pay as well.
Later on, the petitioner argues that they were not given due process regarding the result of the
appeal made by the NATW.
ISSUE.
1.) Whether the petitioner was obliged to give the collegiate faculty non-working holiday pay
or not.
2.) Whether the petitioner was deprived from the right to due process or not.
HELD.
1.) Yes. The petitioner argued that under book V of the Labor Code, they were being paid
under contractual obligation – which was pay them according to the number of hours used
to teach students. The Solicitor General disagreed, that under Article 94 of the Labor Code,
every worker is entitled to holiday pay except for those that work in “retail and service
establishments”. Doing otherwise would deprive the faculty from the right to not
experience “diminuition of pay”.
2.) No. They have sufficiently been heard and fulfilled the “cardinal primary requirements for
due process”. To quote G.R. No. L-65482, they have fulfilled:

“(1) the right to a hearing which includes the right to


present one's case and submit evidence in support thereof;
(2) the tribunal must consider the evidence presented;
(3) the decision must have something to support itself;
(4) the evidence must be substantial, and substantial
evidence means such evidence as a reasonable mind might
accept as adequate to support a conclusion;
(5) the decision must be based on the evidence presented
at the hearing, or at least contained in the record and
disclosed to the parties affected;
(6) the tribunal or body of any of its judges must act on its
or his own independent consideration of the law and facts
of the controversy, and not simply accept the views of a
subordinate;
(7) the board or body should in all controversial questions,
render its decisions in such manner that the parties to the
proceeding can know the various issues involved, and the
reason for the decision rendered. “

The Supreme Court set aside the decision of the NRLC was “set aside” and the Supreme
Court rendered a new decision, which exempts the JRC from giving the faculty holiday
pay. However, the petitioner is required to pay the collegiate faculty the income they would
have earned had it not been for the holiday. Additionally, any extensions to the school
curriculum shall likewise be paid accordingly.

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