FACTS:

The Letran Calamba Faculty and Employees Association filed a complaint against Colegio de San Juan de Letran, Calamba, Inc. for collection of monetary claims due its members. The petitioner alleged that the respondent did not include compensation for teaching overloads in the computation of the thirteenth month pay and did not pay the wage increases required by Wage Order No. 5. The petitioner also claimed that the respondent did not follow the prescribed formula for computing compensation per unit of excess load, did not give salary increases to non-academic personnel, did not pay the balances of tuition fee increases, and did not pay holiday pay. The petitioner filed a separate complaint for money claims with the Department of Labor and Employment. The Labor Arbiter dismissed the money claims cases and the petition to declare the strike illegal. Both parties appealed to the NLRC, and their appeals were dismissed. The petitioner filed a petition for certiorari with the Court of Appeals, but it was dismissed. The petitioner now brings the case to the Supreme Court, contending that the CA erred in holding that the factual findings of the NLRC cannot be reviewed in certiorari proceedings and in not granting their monetary claims.

The petitioner argues that the pay for excess loads should be included in the computation of the faculty members' thirteenth month pay, citing an opinion from the Bureau of Working Conditions of the DOLE. The petitioner also claims that the DOLE Order on which the LA and NLRC based their decisions cannot be applied retroactively. The respondent argues that judicial review in labor cases is limited to issues of jurisdiction or grave abuse of discretion. The respondent asserts that the LA's findings on the non-payment of money claims have sufficient legal and factual bases. The respondent argues that the DOLE Order is mandatory and that a legal opinion from the DOLE supports their position. The respondent claims that the prevailing rule prior to the DOLE Order was to exclude excess teaching load in the computation of a teacher's basic salary and thirteenth month pay.

ISSUES:

1. Whether the non-payment of benefits under Wage Order No. 5 is valid and legal.

2. Whether the computation of salary differentials for excess load is proper.

3. Whether the non-academic members of the union are entitled to wage increases due to "Job Grading".

4. Whether the union members were given their full share in the tuition fee increases.

5. Whether there was non-payment of holiday pay.

6. Whether the findings of fact of the administrative agencies and quasi-judicial bodies are binding upon the court.

7. Whether a teacher's overload pay should be considered in the computation of his or her 13th-month pay.

8. Whether the DOLE Order, which excludes overload pay from the computation of the 13th-month pay, is applicable in the present case.

9. Whether overload pay should be excluded from the computation of the 13th-month pay.

10. Whether or not overtime pay, premium for special holiday, and overload pay should be considered as part of a teacher's regular or basic salary for the computation of the 13th-month pay.

11. Whether or not overload pay may be included as a basis for determining a teacher's 13th-month pay.

RULING:

1. The claim for non-payment of benefits under Wage Order No. 5 fails because the School settled its obligations to its employees in accordance with the agreement reached during the management-employees meeting. The evidence presented shows that the School paid its employees the benefits under Wage Order No. 5.

2. The claim for salary differentials for improper computation of compensation per unit of excess load is dismissed because there were no classes on certain dates during the relevant school years, thus no salary differentials are due.

3. The non-academic members of the union are not entitled to wage increases due to "Job Grading" because the Job Grading system was neither consistent nor implemented for a considerable period of time.

4. The claim that union members were not given their full share in the tuition fee increases is refuted by the evidence presented by the School, which shows that the School incurred a deficit in one school year and paid out a percentage of the increments in tuition fees in the subsequent school years.

5. The claim for non-payment of holiday pay is disproven by the individual pay records, which indicate that the employees are paid for all days worked in the year, including legal holidays.

6. The court upholds the unanimous factual findings of the Labor Arbiter, National Labor Relations Commission (NLRC), and Court of Appeals (CA), unless there is a showing of grave abuse of discretion or the findings were arbitrarily made or in disregard of the evidence on record.

7. The court follows the interpretation of the Bureau of Working Conditions of the Department of Labor and Employment (DOLE), which states that if overload work is performed within a teacher's normal eight-hour work per day, the remuneration for the additional teaching load should form part of the basic wage and be included in the computation of the 13th-month pay.

8. The DOLE Order, which was issued four years after the present case was initiated, cannot be retroactively applied. However, the Court has the final determination of what the law means, and the DOLE Order's interpretation is advisory in nature.

9. The Court finds that overload pay should be excluded from the computation of the 13th-month pay. This is in line with the interpretation of the term "basic salary" in San Miguel Corporation v. Inciong, which excludes compensations or remunerations that are not part of the regular basic salary of the employee.

10. The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that overtime pay, premium for special holiday, and overload pay should not be considered as part of a teacher's regular or basic salary for the computation of the 13th-month pay. Overload pay, being compensation for additional work performed in excess of the regular teaching load, should be considered as extra and not deemed as part of the regular or basic salary. Therefore, overload pay may not be included as a basis for determining a teacher's 13th-month pay.

PRINCIPLES:

• The extraordinary remedy of certiorari is available only in exceptional cases involving jurisdiction or grave abuse of discretion.

• The Court defers to the factual findings of the labor tribunals, unless patently erroneous.

• The Court's jurisdiction in a petition for review on certiorari is limited to reviewing errors of law.

• The Court is not a trier of facts and does not weigh or reevaluate the evidence already considered in the proceedings below.

• The court defers to the expertise and findings of fact of administrative agencies and quasi-judicial bodies, unless there is a showing of grave abuse of discretion or arbitrary disregard of evidence.

• In petitions for review on certiorari, the court sustains the unanimous factual findings of the lower courts when supported by substantial evidence.

• Overload work performed within the teacher's normal eight-hour work per day should be considered as part of the basic pay for the purpose of computing the teacher's 13th-month pay.

• Administrative rulings and circulars are not given retroactive effect.

• The courts have the authority to interpret the law, superseding administrative interpretations.

• The term "basic salary" in the computation of the 13th-month pay excludes compensations or remunerations that do not form part of the regular basic salary.

• The Supplementary Rules and Regulations Implementing Presidential Decree 851 exclude earnings and other remunerations that are not part of the basic salary from the computation of the 13th-month pay.

• Overtime pay, premium for special holiday, and overload pay are additional compensations other than and added to the regular wage or basic salary.

• Overload pay is compensation for additional work performed in excess of the regular teaching load.

• Payments for overload vary and are dependent upon the availability of extra teaching loads, making it not feasible to consider them as part of a teacher's regular or basic salary.