Case Digest (G.R. No. 171594-96)
Facts:
Asia Brewery, Inc. v. Tunay Na Pagkakaisa ng mga Manggagawa sa Asia (TPMA), G.R. Nos. 171594-96, September 18, 2013, the Supreme Court Second Division, Del Castillo, J., writing for the Court.Asia Brewery, Inc. (ABI) is a beverage manufacturer employing about 1,500 workers; TPMA is the certified sole and exclusive bargaining agent for ABI’s regular rank-and-file employees. Negotiations for a new collective bargaining agreement (CBA) for 2003–2006 began after the prior CBA expired in July 2003; after roughly 18 sessions, the parties deadlocked primarily over wages and other economic items. On October 27, 2003 TPMA filed a strike notice with the NCMB; on November 18, 2003 TPMA conducted a strike vote (768 of 840 voted in favor). ABI petitioned the Secretary of Labor to assume jurisdiction under Article 263(g) of the Labor Code on November 20, 2003; TPMA opposed, arguing ABI’s business was not indispensable to the national interest.
On December 19, 2003, the Acting Secretary of Labor issued an order assuming jurisdiction, enjoining strike/lockout, and directing the parties to file position papers; the Order required that ABI provide, among other things, its complete audited financial statements for the past five years, projected financial statements for three years, CBA history, and average monthly salary figures. TPMA filed petitions with the Court of Appeals (CA) seeking to enjoin or annul the Secretary’s assumption of jurisdiction and later to assail the arbitral award.
On January 19, 2004, Secretary of Labor Patricia Sto. Tomas issued an arbitral award granting wage increases totalling P45 (P18, P15, P12 over three years) and awarding HMO benefits with a P1,300 premium per covered employee. Both parties filed reconsideration motions; the Secretary resolved them on January 29, 2004. The parties nevertheless executed and signed a CBA dated August 1, 2003 to July 31, 2006. TPMA filed a certiorari petition with the CA (CA-G.R. SP No. 83168) on April 1, 2004 contesting the arbitral award.
The CA, in a decision dated October 6, 2005, affirmed the Secretary’s December 19, 2003 order, declared the CBA effective August 1, 2003, remanded computation of wage increases to the Secretary, and set the health benefit at P1,390.00. In an amended decision of February 17, 2006, the CA deleted a signing bonus previously awarded and expressly remanded the wage-computation issue to the Secretary to use externally audited financial statements submitted by ABI. ABI alone appealed to the Supreme Court via a Petition for Review on Certiorari...(Subscriber-Only)
Issues:
- Was the person who verified and filed the petition in CA-G.R. SP No. 83168 authorized to represent TPMA, and should the CA have dismissed that petition for lack of authority?
- Did the Court of Appeals err in remanding the wage-increase computation to the Secretary of Labor?
- Did the Court of Appeals err in modifying the Secretary’s award of HMO premium from P1,300.00 ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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