G.R. No. 138516-17 - People vs. Dela Cruz

Petitioner Philippine Appliance Corporation (Philacor) is a domestic corporation manufacturing refrigerators, freezers, and washing machines.
Respondent United Philacor Workers Union-NAFLU is the duly elected collective bargaining representative of Philacor's rank-and-file employees.

During the collective bargaining negotiations (CBA) for the period July 1, 1997, to August 31, 1999, petitioner offered a P4,000 "early conclusion bonus" as a unilateral incentive to hasten negotiations.
After successful conclusion of the CBA negotiations, petitioner paid this early signing bonus.

Upon expiration of the previous CBA, respondent union sent a notice to negotiate a new CBA.
After eleven negotiation meetings in 1999, the union declared a bargaining deadlock on October 22.
Subsequently, on October 26, 1999, the union filed a Notice of Strike with the National Conciliation and Mediation Board (NCMB), Region IV.
A conciliation conference was held on October 30, 1999, with eighteen unresolved items initially. By November 20, 1999, fourteen items were agreed upon, with four remaining unresolved: wages, rice subsidy, signing bonus, and retroactive bonus.
No agreement was reached on the remaining issues. On January 18, 2000, the union went on a strike lasting eleven days, causing operational and financial losses to petitioner.

Labor Secretary Bienvenido E. Laguesma assumed jurisdiction and, on January 28, 2000, ordered the striking workers to return to work and directed petitioner to accept them back.
On April 14, 2000, Secretary Laguesma issued an order fixing wage increases, maintaining rice subsidy and retroactive pay, and granting a P3,000 signing bonus in favor of the company’s proposal. The parties were directed to conclude a CBA incorporating these terms.

On April 27, 2000, petitioner filed a motion for reconsideration objecting to the signing bonus award, arguing it was an incentive and not a demandable or enforceable benefit as no mutually signed CBA had been concluded.
On May 22, 2000, Secretary Laguesma denied the motion, emphasizing the bonus was granted in the previous CBA and the delay in signing was not solely due to the union.
Petitioner filed a Petition for Certiorari before the Court of Appeals; the petition was denied, affirming the Secretary’s order granting the signing bonus as petitioner’s unilateral offer remained outstanding.
Petitioner’s motion for reconsideration before the CA was also denied.

The sole issue raised in this petition is whether the Court of Appeals gravely abused its discretion by affirming the order granting the signing bonus, contrary to the "Caltex doctrine."

Whether the award of a signing bonus by the Secretary of Labor is proper and demandable given the circumstances of the failed CBA negotiations and subsequent strike.

Whether the petitioner is bound to pay the signing bonus despite the absence of a mutually concluded CBA covering such benefit.