G.R. No. 146073 - Acedera vs. International Container Terminal Services

Petitioners-appellants are employees of International Container Terminal Services, Inc. (ICTSI) and serve as officers/members of the Associated Port Checkers & Workers Union-ICTSI (APCWU-ICTSI), a duly registered local affiliate of the Associated Port Checkers & Workers Union (APCWU).
ICTSI, a private company, began operations in 1988 and initially computed employees’ wages by using 304 days—the presumed working days in a year—as the divisor.

On September 28, 1990, ICTSI entered into its first CBA with APCWU, setting a five-year term until September 28, 1995.
The CBA was renegotiated and renewed as a second CBA effective from September 29, 1995, for another five years.
Both CBAs contained an identical provision on work hours and days: a five-day work week (or 250 working days per year) without specifying the divisor for computing wages.
Despite the CBA’s implicit indication of a 250-day work year, ICTSI continued using either a 304-day or, later on, a 365-day divisor for wage computation.

On November 10, 1990, the Regional Tripartite Wage and Productivity Board (RTWPB) in the National Capital Region issued a wage order mandating a P17.00 daily wage increase for workers earning P125.00 per day or lower.
Acting on a proposal by the union’s president and some members, ICTSI shifted from using 304 days to using 365 days as the divisor to compute wages, even though the employees’ work schedule was based on a five-day (250-day) work week specified in the CBA.

In early 1997, ICTSI embarked on a retrenchment program that resulted in the layoff of its on-call employees, triggering labor unrest.
The APCWU responded by filing a notice of strike, citing both the retrenchment and the disputed computation of wages (i.e., the use of the 365-day divisor) as causes of action.
The wage computation dispute was referred to the Labor Arbiter when APCWU filed a complaint on behalf of its members and similarly situated employees.
On February 26, 1997, APCWU initially filed its complaint with the Labor Arbiter, which later saw its procedural position revived and repositioned by additional filings, including a Complaint-in-Intervention with Motion to Intervene by certain employees (petitioners-appellants).

The Labor Arbiter ruled in favor of a 250-day divisor for computing wages, ordering ICTSI to pay wage differentials for underpayment over a specified period.
The National Labor Relations Commission (NLRC) reversed certain aspects of the Labor Arbiter’s decision by dismissing APCWU’s complaint as lacking merit, yet it affirmed the denial of petitioners-appellants’ intervention.
Both APCWU and the petitioners-appellants sought relief via petitions for certiorari. The Court of Appeals dismissed APCWU’s petition on procedural grounds and likewise dismissed the petitioners-appellants’ petition, holding that:

Petitioners-appellants were already adequately represented by APCWU,
Their intervention was superfluous, and
Issues such as the Certificate of Non-Forum Shopping (with only one signature) failed to substantiate a meritorious claim.

They claimed that the Court of Appeals erred by basing its decisions on the CBA provisions and relevant Supreme Court precedents that rendered their intervention unnecessary.
They argued for the right to intervene under Rule 19 of the 1997 Rules of Civil Procedure, contending that they have a distinct legal interest in the case’s outcome since they would suffer direct loss should the union fail to prosecute the case efficiently.
They asserted that procedural deficiencies in representing their interests, such as only one petitioner signing the Certificate of Non-Forum Shopping, further justified their intervention.

Whether petitioners-appellants have the right to intervene in the labor dispute given that their interests are already represented by the union (APCWU).
Whether the intervention under Rule 19 of the 1997 Rules of Civil Procedure is proper when a representative (the union) is already prosecuting the case.

Whether ICTSI’s practice of computing wages using a 365-day divisor—despite a work schedule based on a five-day (250-day) work week as agreed in the CBA—is legally sustainable.
Whether the absence of an express provision in the CBA on the divisor renders the union’s challenge to the wage computation untenable.

Whether procedural shortcomings, such as the non-filing of requisite position papers and failure to secure court extensions, undermine the petitioners-appellants’ position.
Whether the dismissal of the petitions, on technical as well as substantive grounds, is justified in view of established legal doctrines on representation and estoppel.