Case Digest (G.R. No. 118069)
Facts:
Producers Bank of the Philippines v. National Labor Relations Commission and Producers Bank Employees Association, G.R. No. 118069, July 26, 1999, Supreme Court Third Division, Romero, J., writing for the Court.At the time the dispute began, Producers Bank of the Philippines (now First Philippine International Bank) had been placed under conservatorship by the Central Bank of the Philippines (now Bangko Sentral ng Pilipinas). The Producers Bank Employees Association sought implementation of two collective bargaining agreement (CBA) provisions: Article XI, Section 1 (retirement plan) and Article X, Section 4 (uniform allowance). The bank’s acting conservator objected to implementing those provisions, producing an impasse that lasted about six months.
The union filed a complaint for unfair labor practice and for violation of the CBA before the Labor Arbiter. The Labor Arbiter dismissed the complaint on the ground that, because the bank was under conservatorship, the conservator was not compelled to implement LMRC resolutions or CBA provisions if enforcement would not be in the bank’s best interest. The union appealed to the National Labor Relations Commission (NLRC). The NLRC reversed the Labor Arbiter and ordered the bank to implement the contested CBA provisions, holding that workers’ protection under the Labor Code and social legislation, grounded in the Constitution, could not be subordinated to the bank’s interests.
Unhappy with the NLRC decision, petitioner sought relief from the Supreme Court. In its petition the bank argued, among other points, that (a) the conservator had authority under Section 28‑A of the Central Bank law to disallow implementation of the CBA provisions; (b) the Labor Arbiter and NLRC lacked jurisdiction because the dispute was subject to voluntary arbitration under Article 261 of the Labor Code; and (c) since the employees had retired, they lacked the personality to litigate the claim...(Subscriber-Only)
Issues:
- Did the petitioner forfeit or otherwise waive the defense that the Labor Arbiter and the NLRC lacked jurisdiction to entertain the union’s complaint?
- Could the conservator lawfully prevent the implementation of valid CBA provisions (Article XI, Sec. 1; Article X, Sec. 4) on the ground of conservatorship authority?
- Did the retirement of employees deprive them (or their union) of the personality to prosecut...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)