Title
Shell Oil Workers Union vs. Shell Company of the Philippines
Case
G.R. No. L-30658-59
Decision Date
Mar 31, 1976
Unions sought overtime pay including fringe benefits under *NAWASA* ruling; SC upheld CBA terms, ruling benefits irregular, affirming Shell's compliance with labor laws.

Case Digest (G.R. No. L-30658-59)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved
    • Petitioners:
      • Shell Oil Workers Union
      • Shell & Affiliates Supervisors' Union
    • Respondents:
      • Shell Company of the Philippines (employer)
      • Court of Industrial Relations (CIR)
  • Procedural History
    • Initial Filings in Trial Court
      • Two separate cases were filed:
        • CIR Case No. 2410-V ("Shell Oil Workers Union vs. The Shell Company and its Managers") filed on May 12, 1967.
ii. CIR Case No. 2411-V ("Shell and Affiliates Supervisors' Union vs. Shell Company of the Philippines, Ltd. and its General Managers") filed on May 13, 1967.
  • Both cases involved claims for additional overtime pay based on allegations that the employees were not receiving the full overtime benefits due.
  • Respondent’s Initial Position
    • On May 23, 1967, Shell Company filed a motion to dismiss which was later withdrawn on July 19, 1967.
    • An Answer was subsequently filed on July 27, 1967, asserting that overtime work had been and was being compensated in accordance with both the law and the existing collective bargaining agreement.
    • The Respondent also argued that:
      • The computation method for overtime pay agreed upon in the collective bargaining agreement was correct.
ii. The ruling in the NAWASA case (National Waterworks & Sewerage Authority vs. NWSA Consolidated Unions, L-18938, August 31, 1964) was inapplicable to their situation. iii. Claims for overtime pay purportedly filed beyond the allowable three-year period were time-barred.
  • Agreed Stipulations and Evidence
    • The parties agreed that the trial court would decide the case on the basis of the testimony of Mr. B. Figueroa, Industrial Relations Manager of Shell Company.
    • The following exhibits were stipulated as part of the agreement:
      • Exhibit "A-Petitioner" and Exhibit "1-Respondent": The collective bargaining agreement in force covering a period from August 1966 to December 31, 1969.
ii. Exhibit "A-1, Petitioner" and Exhibit "1-A, Respondent": Detailed premium rates, allowances, and computation methods for overtime pay. iii. Additional Exhibit "B": A description of fringe benefits, noting that:
  • The Tin Factory Incentive pay had ceased due to the closure of the factory in May 1966.
  • Fringe benefits were occasionally not enjoyed regularly, and conditions precedent applied to their entitlement.
  • Judicial Notice: Both parties agreed the court could take judicial notice of the NAWASA case records and refer to them as necessary.
  • Collective Bargaining Agreement and Claims Raised
    • Petitioners’ Claim
      • The petitioners argued that the overtime pay should be recomputed by including the money value of fringe benefits.
      • They relied on the ruling in the NAWASA case which held that, for overtime computation, the regular wage must include several agreed-upon payments, including fringe benefits.
      • Their theory was that the fringe benefits provided, though not always regularly enjoyed by all employees, should be considered in the calculation of overtime compensation.
    • Respondents’ Defense
      • The respondent maintained that the overtime compensation had been correctly computed based on the basic wage as stipulated in the collective bargaining agreement.
      • They argued that the NAWASA decision was not applicable since:
        • The fringe benefits were not regularly enjoyed by the employees for the requisite period.
ii. The existing collective bargaining agreement should govern the method of computation.
  • Emphasis was placed on the contractual term that provided for a premium rate significantly above the statutory minimum prescribed by Commonwealth Act 444.
  • Court Decisions
    • Trial Court Decision
      • On January 29, 1968, the trial court denied both petitions for additional overtime pay due to a lack of basis.
    • Court of Industrial Relations en Banc
      • On February 2, 1968, petitioners elevated the case and sought reconsideration.
      • On July 31, 1968, the Court of Industrial Relations en banc issued a resolution denying the petitioners’ motion for reconsideration, affirming the trial court’s decision.
    • Supreme Court Review
      • The petition for review on certiorari was then elevated to the Supreme Court.
      • The core contention before the Court was whether the NAWASA ruling was applicable to the present case, thereby justifying the recomputation of overtime pay by including fringe benefits.

Issues:

  • Main Issue
    • Whether the ruling in the NAWASA case (National Waterworks & Sewerage Authority v. NWSA Consolidated Unions, L-18938, August 31, 1964) is applicable for the recomputation of overtime pay in the present case.
  • Sub-Issues
    • Whether the inclusion of fringe benefits in the computation of overtime pay is justified, given that such benefits may not be regularly and continuously enjoyed by all employees.
    • Whether the collective bargaining agreement, as the law of the parties, precludes any alteration in the mode of computing overtime compensation based on the NAWASA decision.
    • Whether there is any contractual or legal basis to extend the claims for overtime pay beyond the established limitations (i.e., the prescribed three-year period).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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