Facts:
Philippine Geothermal, Inc. Employees Union (PGIEU), the certified bargaining agent of the rank-and-file employees of
Chevron Geothermal Phils. Holdings, Inc., executed a Collective Bargaining Agreement on July 31, 2008 effective from November 1, 2007 to October 31, 2012 which, under Article VII, Section 1, provided a P260,000.00 lump sum effective November 1, 2007 and across-the-board increases of P1,500.00 effective November 1, 2008 and November 1, 2009, with implementing guidelines set out in Annex D specifying eligibility by date of regularization. On September 20, 2009 the petitioner’s President sent a letter alleging improper implementation and possible salary distortion; the respondent replied insisting that its remuneration policy of “similar values for similar jobs” and annual adjustments to hiring rates explained the differences in pay. The petitioner, with respondent’s approval, submitted the dispute to Voluntary Arbitration before the National Conciliation and Mediation Board (NCMB), contending that respondent improperly granted the P1,500.00 increase to probationary employees Sherwin Lanao and Jonel Cordovales prior to their regularization (they were regularized on January 1, 2010 and April 16, 2010, respectively), thereby obliterating intended salary distinctions; respondent countered that the higher pay reflected higher hiring rates at their dates of engagement and that it complied with the CBA. The Voluntary Arbitrator rendered a Decision dated August 16, 2010 in favor of respondent. The petitioner filed a Petition for Review under Rule 65 with the Court of Appeals on September 22, 2010. The Court of Appeals rendered a Decision on November 5, 2012 dismissing the petition and sustaining the NCMB decision; the petitioner’s Motion for Reconsideration filed November 28, 2012 was denied by resolution dated May 17, 2013. The petitioner then sought relief in this Court by a petition under Rule 45, which resulted in the present decision dated January 24, 2018.
Issues:
- Whether the Court of Appeals gravely erred in holding that Chevron Geothermal Phils. Holdings, Inc. did not violate the CBA in granting the P1,500.00 wage increase to Lanao and Cordovales when they had not yet attained regular status? II. Whether the Court of Appeals gravely erred in holding that the grant of wage increases to Lanao and Cordovales constituted a valid exercise of management prerogatives by the respondent? III. Whether the Court of Appeals erred in not ordering respondent to increase the rates of other regular employees to maintain the differential between their rates and those of employees allegedly granted premature wage increases?
Ruling:
Ratio:
Doctrine: