G.R. No. 113856 - Samahang Manggagawa sa Top Form Manufacturing vs. National Labor Relations Commission

Petitioner: Samahang Manggagawa sa Top Form Manufacturing – United Workers of the Philippines (SMTFM-UWP), the certified collective bargaining representative for all regular rank-and-file employees of Top Form Manufacturing Philippines, Inc.
Respondents: The National Labor Relations Commission (NLRC) and private respondent Top Form Manufacturing Philippines, Inc.
The dispute arose from issues in collective bargaining, where economic issues regarding wage increases were discussed.

On February 27, 1990, both parties held a collective bargaining negotiation at the Milky Way Restaurant in Makati, Metro Manila to address unresolved economic matters, with special discussion on Article VII (Wages) of the collective bargaining agreement (CBA).
During these negotiations, the union proposed that any future government-mandated wage increase be granted across-the-board.
Management countered by noting their previous act of granting a P25.00 across-the-board increase and requested the union to defer the incorporation of such a provision.

A joint affidavit dated January 30, 1992, by union members reaffirmed that the union had insisted on an automatic across-the-board wage increase and relied on management’s previous undertakings.
On October 24, 1991, the union, through its legal counsel, sent a letter demanding that Top Form Manufacturing fulfill its earlier pledge of granting across-the-board wage increases under the new Wage Orders.
It was emphasized that the union had initially agreed to retain the deferred proposal based on the promise made during negotiations.

Wage Order No. 01 (issued October 15, 1990) mandated a P17.00 per day increase for employees earning P125.00 or less.
Wage Order No. 02 (issued December 20, 1990) provided a P12.00 daily increase for employees earning P140.00 or less.
Instead of applying these increases across-the-board, the private respondent implemented a graduated scheme: employees earning below set thresholds received the full increase, while those above received lesser increments—purportedly to avoid wage distortion.

The union filed a complaint with the NCR NLRC alleging that the employer committed an unfair labor practice by bargaining in bad faith and engaging in discriminatory wage practices by not implementing the wage orders uniformly.
The issues involved whether the employer’s negotiations results—particularly the promise during bargaining—could be deemed binding even though they were not incorporated into the final CBA.
The Labor Arbiter, on March 11, 1992, dismissed the complaint, stating that there was no binding agreement on an across-the-board wage increase and that the employer’s scheme was legally justifiable.
Subsequent NLRC decisions, including the Resolution of April 29, 1993, and a later denied petition for reconsideration, affirmed the decision dismissing the union's claims.

Whether private respondent committed an unfair labor practice by failing to implement an automatic across-the-board wage increase in light of its earlier promise during collective bargaining.
Whether the union’s reliance on negotiation minutes—which were not incorporated into the final CBA—can establish a binding contractual commitment on the employer.

Whether the scheme of differential wage increases adopted by the private respondent resulted in significant wage distortion within its wage structure.
Whether the varied implementation of Wage Orders Nos. 01 and 02 amounts to discrimination against certain groups of employees.