Case Digest (G.R. No. 195297) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Coca-Cola Bottlers Philippines, Inc. (“CCBPI”) vs. Iloilo Coca-Cola Plant Employees Labor Union (ICCPELU), Wilfredo L. Aguirre represented the union members, all regular route drivers and helpers employed at CCBPI’s Ungka, Pavia, Iloilo City plant. Under the Collective Bargaining Agreement (CBA) effective during the dispute, the normal work week for daily-paid workers consisted of Monday to Friday, eight hours daily, and one Saturday of four hours, “provided, however, that any worker required to work on Saturday must complete the scheduled shift for the day and shall be entitled to the premium pay…,” and further stipulating that management “has the option to schedule work on Saturdays on the basis of operational necessity.” On July 1, 2005, CCBPI informed the union that it would cease scheduling routine Saturday work beginning July 2, 2005, citing cost-saving and declining revenues. The union filed a grievance, but after voluntary arbitration before the National Conciliation Case Digest (G.R. No. 195297) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation operating a manufacturing plant in Ungka, Pavia, Iloilo City.
- Iloilo Coca-Cola Plant Employees Labor Union (ICCPELU), represented by Wilfredo L. Aguirre, comprises regular route drivers and helpers employed by CCBPI.
- CBA Provisions and Dispute Origin
- Article 10, Section 1 of the Collective Bargaining Agreement (CBA): normal work week is Monday–Friday (8 hours/day) plus Saturday (4 hours). Article 11, Section 1(c) grants management the “option to schedule work on Saturdays on the basis of operational necessity,” and Article 11, Section 2(c) prescribes premium pay for Saturday work.
- On July 2, 2005, CCBPI ceased scheduling Saturdays routinely—citing cost savings and decreased revenues—and thereafter scheduled Saturday maintenance work only as needed. ICCPELU filed a grievance, alleging violation of the CBA.
- Procedural History
- NCMB voluntary arbitration (Sept. 7, 2006): panel ruled for CCBPI—held employees not entitled to basic pay if they did not work Saturdays and that CCBPI could not be compelled to provide Saturday work. Motion for reconsideration denied Oct. 24, 2006.
- Court of Appeals (CA) (June 23, 2010): reversed arbiter’s decision; ordered CCBPI to schedule 4-hour Saturdays, pay wages + premium from July 2, 2005 onward. CA denied reconsideration Oct. 19, 2010.
- CCBPI filed Rule 45 petition for review on certiorari to the Supreme Court.
Issues:
- Does the CBA mandate that CCBPI schedule Saturday work for its employees?
- Did the discontinuance of Saturday work ripen into a company practice constituting a prohibited diminution of benefits, entitling employees to pay for Saturdays they did not work?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)