Case Digest (G.R. No. 104682)
Facts:
The case involves Capitol Wireless, Inc. (petitioner) and Kilusan Maka-Manggagawa sa Capwire (NAFLU) (respondent). On November 15, 1990, the petitioner and the respondent signed a collective bargaining agreement (CBA) that was effective for five years, from July 1, 1990, to June 30, 1995. The CBA included a provision in Section 2 of Article XIV regarding wages, which stipulated specific across-the-board increases for rank-and-file employees over the years. Following the signing of the CBA, the Regional Tripartite Wages and Productivity Board of the National Capital Region issued several wage orders that mandated increases in the statutory minimum wage for all private sector workers. These included Wage Order No. NCR-01, which mandated an increase effective November 1, 1990; Wage Order No. NCR-01-A, which supplemented the first order; and Wage Order No. NCR-02, which provided additional increases effective January 8, 1991.
The petitioner implemented these wage increases onl...
Case Digest (G.R. No. 104682)
Facts:
Background of the Case
- Petitioner Capitol Wireless, Inc. and respondent Kilusan Maka-Manggagawa sa Capwire (NAFLU) signed a Collective Bargaining Agreement (CBA) on November 15, 1990, effective from July 1, 1990, to June 30, 1995.
- The CBA included a provision (Section 2, Article XIV) granting across-the-board wage increases to employees over three years, with the stipulation that any government-mandated wage increases would be "over and above" the benefits granted under the CBA.
Wage Orders Issued
- After the CBA was signed, the Regional Tripartite Wages and Productivity Board of the National Capital Region issued the following wage orders:
- Wage Order No. NCR-01: Mandated an across-the-board daily wage increase effective November 1, 1990.
- Wage Order No. NCR-01-A: Supplemented NCR-01, applying the P17.00 increase to workers earning up to P125.00 per day.
- Wage Order No. NCR-02: Provided a provisional wage increase of P12.00 per day effective January 8, 1991, for workers earning up to P142.00 per day.
Implementation of Wage Orders
- Petitioner implemented the wage increases only for employees earning up to P125.00 (under NCR-01 and NCR-01-A) and up to P142.00 (under NCR-02).
- Private respondent NAFLU argued that the CBA required the government-mandated increases to be granted to all employees without regard to the wage ceilings specified in the wage orders.
Dispute and Arbitration
- The dispute was submitted to voluntary arbitration before the National Conciliation and Mediation Board (NCMB).
- The Voluntary Arbitrator ruled in favor of NAFLU, ordering petitioner to grant the wage increases to all employees covered by the CBA, disregarding the wage ceilings.
Issue:
- Whether the phrase "over and above" in the CBA requires petitioner to grant government-mandated wage increases to all employees, regardless of the wage ceilings specified in the wage orders.
- Whether the Voluntary Arbitrator erred in interpreting the CBA provision and disregarding the wage ceilings imposed by the wage orders.
- Whether the implementation of the wage orders would result in wage distortions.
Ruling:
- The Supreme Court granted the petition and reversed the decision of the Voluntary Arbitrator.
- The Court held that the wage orders applied only to employees earning up to the specified ceilings (P125.00 under NCR-01 and NCR-01-A, and P142.00 under NCR-02).
- The CBA provision should be read in harmony with the wage orders, and the government-mandated increases should be granted only to employees covered by the wage orders.
- Any wage distortions resulting from the wage increases could be remedied through the procedures provided under Article 124 of the Labor Code.
Ratio:
- (Unlock)