Case Digest (G.R. No. 229396) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Nippon Paint Philippines, Inc. (petitioner) vs. Nippon Paint Philippines Employees Association (respondent), G.R. No. 229396, decided June 30, 2021, the parties initially entered into a Collective Bargaining Agreement (CBA) effective January 1, 2007 to December 31, 2011. Article 13, Section 1 of the 2007 CBA granted all union members premium holiday pay—200% of daily rate if unworked, 300% if worked—on enumerated regular holidays. In December 2009, Republic Act No. 9849 declared Eidul Adha a regular holiday. Consequently, in 2010 and 2011, petitioner’s employees received additional holiday pay for Eidul Adha, although it was not listed in the 2007 CBA. On March 21, 2012, the parties executed a new CBA covering 2012–2016, again without mentioning Eidul Adha. Thereafter, petitioner discontinued the special holiday pay for Eidul Adha, attributing the prior payments to a payroll system error. Respondent filed a complaint with the National Conciliation and Mediation Board, Regiona Case Digest (G.R. No. 229396) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and CBA terms
- Nippon Paint Philippines, Inc. (petitioner) and Nippon Paint Philippines Employees Association (NIPPEA; respondent) executed a Collective Bargaining Agreement (2007 CBA) effective January 1, 2007 to December 31, 2011
- Article 13, Section 1 of the 2007 CBA provided:
- regular holidays enumerated therein paid at 100% of daily rate even if unworked
- premium pay of 200% for unworked regular holidays, 300% for worked regular holidays
- Eidul Adha declared regular holiday and company practice
- Republic Act No. 9849 (Dec. 11, 2009) declared Eidul Adha as national regular holiday
- In 2010 and 2011, petitioner’s payroll system paid Eidul Adha holiday remuneration in line with company practice
- 2012 CBA renewal and cessation of pay
- New CBA (2012–2016) executed March 21, 2012 omitted Eidul Adha from the list of regular holidays
- Petitioner corrected alleged payroll “glitch” and did not pay additional holiday remuneration for Eidul Adha in 2012
- Procedural history
- Dispute referred to Voluntary Arbitrator (VA); October 31, 2014 VA Decision held payments were system error, no company practice, no refund required
- NIPPEA appealed via Rule 43 petition before Court of Appeals (CA); July 18, 2016 CA Decision set aside VA decision, found company practice, remanded for computation; November 28, 2016 CA Resolution denied reconsideration
- Petitioner filed Rule 45 petition before the Supreme Court
Issues:
- Entitlement to additional 100% holiday pay in 2012 and 2013 for Eidul Adha
- Entitlement of petitioner to refund payments made in 2010 and 2011 for Eidul Adha holiday on grounds of system error
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)