Case Digest (G.R. No. 218010)
Facts:
Fernand O. Maternal et al. v. Coca‑Cola Bottlers Phils., Inc., G.R. Nos. 218010 and 248662, February 06, 2023, Supreme Court Second Division, Lopez, J., writing for the Court. The petitions are consolidated and resolve challenges to the Court of Appeals decisions in CA‑G.R. SP Nos. 126819 and 137718 that rejected rank‑and‑file employees’ claims for recurring bonuses from respondent Coca‑Cola Bottlers Phils., Inc. (CCBPI).The petitioners are numerous CCBPI rank‑and‑file employees who allege entitlement to yearly bonuses. Between 1997 and 2007 CCBPI, under various managers, granted a series of “one‑time” bonuses, gifts, economic assistance, and a “one‑time transition bonus” (details of dates, recipients and computation appear in the records). Beginning in 2008 the new management discontinued those ad hoc grants and stated bonuses would thereafter be performance‑based. When no performance bonuses materialized for 2008–2009, the employees and their union filed consolidated complaints for nonpayment of bonuses and attorney’s fees.
Before the Labor Arbiter, the employees prevailed: the April 18, 2011 Decision ordered CCBPI to pay yearly bonuses for 2008–2010 (equivalent to monthly pay multiplied by the number of years unpaid) and attorney’s fees. On appeal the National Labor Relations Commission (NLRC) affirmed in a February 29, 2012 Decision, later modifying the award by resolution dated July 25, 2012 to set the yearly bonus at two‑thirds (2/3) of basic monthly pay. CCBPI sought certiorari relief with the Court of Appeals (CA‑G.R. SP No. 126819); the employees pursued execution and further motions, and the labor arbiter issued writs of execution that led to partial garnishments and payment by manager’s checks.
The NLRC later entertained a petition for annulment and, by June 23, 2014 Resolution, granted the petition and ordered cessation of executory writs. CCBPI sought restitution of amounts paid; the employees filed a new certiorari petition with the Court of Appeals (CA‑G.R. SP No. 137718). The CA in CA‑G.R. SP No. 126819 (Aug. 19, 2014) granted CCBPI’s petition and declared void the NLRC decisions, holding the bonuses were not demandable and did not ripen into a company practice; its denial of reconsideration was promulgated Mar. 17, 2015. ...(Pro-only)
Issues:
- Is this Court bound by its minute resolutions in G.R. Nos. 206506, 214996, 215681, and 214149 involving other Coca‑Cola employees?
- Did CCBPI’s discontinuation of the “one‑time” bonuses constitute unlawful diminution of benefits under Article 100 of the Labor Code?
- Had the employees’ entitlement to year‑end bonuses (G.R. No. 248662) become final and executory so as to bar further review?
- Did the NLRC commit grave abuse of discretion by reversing a labor...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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