Case Digest (G.R. No. 50184)
Facts:
Citibank Phils. Employees Union Natu v. The Honorable Minister of Labor and Citibank, N.A., G.R. No. 50184, April 11, 1980, Supreme Court Second Division, Barredo, J., writing for the Court.The petition arose from a voluntary arbitration between First National City Bank (private respondent/Citibank) and its employees represented by FNCB Employees Union NATU (petitioner). The parties submitted the question whether monthly-paid bank employees were legally entitled to holiday pay under Article 208 (now Art. 94) of the Labor Code to their mutually chosen voluntary arbitrator, Atty. Ruben F. Santos. The arbitrator rendered an award dated December 1975 ordering Citibank to pay holiday pay on the ground that the monthly salary did not include compensation for unworked holidays. Citibank partially complied, paying accrued holiday pay covering November 1974 to December 1975.
After promulgation of the Integrated Implementing Rules of the Labor Code under P.D. 850 (Rule IV, Book Three, Section 2) and issuance of the Secretary of Labor’s Policy Instructions No. 9 (1976), Citibank stopped further payments, relying on the Minister’s presumption that uniformly paid monthly employees receiving not less than the maximum monthly minimum wage were already paid for legal holidays. The union filed a motion for execution to enforce the voluntary arbitrator’s award.
The Executive Labor Arbiter (Guillermo C. Medina) on December 13, 1976 denied Citibank’s motion to quash the writ of execution and ordered Citibank to continue paying the unworked regular holidays. The National Labor Relations Commission affirmed that order by resolution of December 19, 1977. The respondent Minister of Labor, however, issued an order dated February 19, 1979 setting aside the NLRC resolution, granting the...(Subscriber-Only)
Issues:
- Did the Minister of Labor act within authority in setting aside the NLRC resolution and quashing execution of the voluntary arbitrator’s award on the basis of subsequently promulgated implementing rules and Policy Instructions No. 9?
- Can a voluntary arbitrator’s award incorporated into a collective bargaining agreement be modified or set aside on the ground that its implementation would contravene public policy (i.e., that paying abo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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