Title
Manila Central Line Corp. vs. Manila Central Line Free Workers Union-NFL
Case
G.R. No. 109383
Decision Date
Jun 15, 1998
CBA deadlock between Manila Central Line Corp. and union led to compulsory arbitration; SC upheld labor arbiter's retroactive CBA terms, signing bonus, and jurisdiction.

Case Digest (G.R. No. 109383)
Expanded Legal Reasoning Model

Facts:

Background of the Case:

  • The case involves a collective bargaining deadlock between Manila Central Line Corporation (petitioner) and Manila Central Line Free Workers Union-National Federation of Labor (private respondent).
  • The parties' collective bargaining agreement (CBA) expired on March 15, 1989, and they failed to reach a new agreement despite negotiations.

Conciliation Efforts:

  • On October 30, 1989, the union sought the assistance of the National Conciliation and Mediation Board (NCMB), but the deadlock remained unresolved.

Filing of Petition for Compulsory Arbitration:

  • On February 9, 1990, the union filed a Petition for Compulsory Arbitration with the National Labor Relations Commission (NLRC).
  • During the initial hearing, both parties agreed to submit the case for compulsory arbitration and were required to submit their position papers and proposals.

Labor Arbiter's Decision:

  • On September 28, 1990, the labor arbiter rendered a decision, directing the parties to execute a new five-year CBA retroactive to the expiry date of the previous CBA (March 15, 1989).
  • The decision included provisions on commission rates, incentive pay, salary increases, and a signing bonus.

Appeal to the NLRC:

  • The petitioner appealed the labor arbiter's decision, but the NLRC dismissed the appeal on October 10, 1991, and denied the motion for reconsideration on March 11, 1993.

Petition to the Supreme Court:

  • The petitioner filed a petition for certiorari with the Supreme Court, raising several issues, including the jurisdiction of the labor arbiter, the factual findings, and the retroactivity of the CBA.

Issues:

  • Jurisdiction of the Labor Arbiter:
    • Whether the labor arbiter had jurisdiction to render the decision, given the policy favoring voluntary arbitration under the Labor Code.
  • Factual Findings:
    • Whether the labor arbiter and the NLRC erred in their factual findings regarding:
      • The increase in commission rates, incentive pay, and salaries.
      • The grant of a P500.00 signing bonus.
      • The retroactive effectivity of the CBA to March 15, 1989.
  • Disregard of Agreed Provisions:
    • Whether the labor arbiter disregarded provisions of the old CBA that the parties had retained and agreed upon.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court dismissed the petition for lack of merit, upholding the decision of the labor arbiter and the NLRC. The Court affirmed the jurisdiction of the labor arbiter, the factual findings, the retroactivity of the CBA, and the reasonableness of the terms imposed.

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