Case Digest (G.R. No. 102636)
Facts:
Metropolitan Bank & Trust Company Employees Union-ALU-TUCP and its president Antonio V. Balinang, petitioners, filed G.R. No. 102636; the case was decided September 10, 1993, by the Supreme Court Third Division, Vitug, J., writing for the Court.On 25 May 1989, Metropolitan Bank & Trust Company (the bank) and MBTCEU executed a collective bargaining agreement (CBA) granting a P900 monthly wage increase effective 1 January 1989, P600 effective 1 January 1990, and P200 effective 1 January 1991. The bank refused to extend the first P900 increase to probationary employees; only regular employees as of 1 January 1989 received it.
Republic Act No. 6727 took effect on 1 July 1989, increasing statutory minimum wages by P25 per day (P750 monthly) and providing that increases granted by employers within three months prior to the Act’s effectivity may be credited, with an express mechanism for correcting any resulting "wage distortion" through voluntary settlement or compulsory arbitration before the regional branches of the National Labor Relations Commission (NLRC). Pursuant thereto, the bank granted the P25/day increase to its probationary employees and those promoted to regular status before 1 July 1989 whose daily rate was P100 or below, but refused the increase to regular employees who were already earning over P100 and who had received the P900 CBA increase.
The union contended that the bank’s partial implementation of RA 6727 created a wage distortion by substantially contracting the intentional P900 gap between (a) probationary/promoted employees and (b) regular employees as of 1 January 1989. The parties submitted to compulsory arbitration before Labor Arbiter Eduardo J. Carpio. On 5 February 1991 the labor arbiter found a wage distortion and ordered the bank to restore the P900 CBA wage gap by granting the complainants a P750 monthly increase effective 1 July 1989.
The bank appealed to the NLRC. On 31 May 1991 the NLRC Second Division reversed (2–1), holding that the intentional quantitative differences in the bank’s salary structure were maintained and that the reductions were not so significant as to obliterate or severely contract those differences; it dismissed the complaint. Presiding Commissioner Edna Bonto-Perez dissented, finding the contraction to be approximately eighty-three percent and therefore severe, but she rejected the labor arbiter’s across-the-board P750 award as inequitable and proposed correction pursuant to the formula in Wage Order No. IV-02 (RTWP Commission). The MBTCEU’s motion for reconsideration before the NLRC was denied.
The union then filed this petition for certiorari with the Supreme Court, alleging grave abu...(Pro-only)
Issues:
- Did the NLRC commit grave abuse of discretion in refusing to find a wage distortion arising from the bank’s partial implementation of Republic Act No. 6727?
- If a wage distortion existed, was the NLRC’s refusal to grant the corrective relief sought—specifically an across-the-board P25 per day (P750 monthly) increase—a...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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