G.R. No. 237729 - Social Housing Employees Association, Inc. vs. Social Housing Fice Corp.

On December 24, 2008, the Social Housing Finance Corporation (SHFC), a government-owned and controlled corporation (GOCC), and the Social Housing Employees Association, Inc. (SOHEAI), the legitimate labor organization for its rank-and-file employees, entered into a CBA.
This initial agreement established the framework for labor-management relations between the parties.

On December 22, 2011, the parties renegotiated economic provisions, resulting in adjustments and additional benefits including:

Increase in emergency leave from 3 to 5 days annually.
Extension of insurance and health benefits covering accidents or injuries during commuting.
Increment in transportation allowance from ₱300 to ₱500 per month.
Enhancement of funeral/bereavement assistance from ₱10,000 to ₱20,000.
Increase in children’s allowance from ₱30 to ₱100 per child per month.
Raised employee activities subsidy from ₱877 to ₱1,200 per employee per year.
Adjustment of the corporate share in the Provident Fund from 15% to 25%.
Introduction of an anniversary bonus of ₱3,000 in line with applicable administrative orders.

A similar set of economic provisions was incorporated into a subsequent CBA entered on December 3, 2013 following the failure of mediation.

On January 17, 2012, the Governance Commission for GOCCs (the GCG) informed SHFC that it lacked authority to negotiate beyond existing standards due to:

Executive Order (EO) No. 7 (issued September 8, 2010), which imposed a moratorium on increases in salaries, allowances, incentives, and other benefits in GOCCs.
Republic Act (RA) No. 10149 (enacted June 6, 2011), which mandated that changes in the compensation framework for GOCC employees must be approved by the President.

Consequently, SHFC revoked the new benefits and increases, effective immediately.

SOHEAI, aggrieved by the revocation and arguing that the action violated the policy on non-diminution of benefits, requested reconsideration which was ultimately denied by SHFC.
SOHEAI further alleged that the annual State of the Nation Address (SONA) bonus of ₱50,000 per employee had ripened into a regular benefit.
After exhausting internal grievance mechanisms, SOHEAI pursued preventive mediation with the National Conciliation and Mediation Board and eventually submitted the matter to the Panel of Voluntary Arbitrators (PVA).

On May 12, 2015, the PVA ruled in favor of SOHEAI, ordering SHFC to comply with the terms of the 2011 and 2013 CBAs and declaring the SONA bonus as a regular benefit, including directing the payment of unpaid bonuses.
On June 25, 2015, SHFC elevated the case to the Court of Appeals (CA) via a Petition for Review under Rule 43 of the Rules of Court, asserting:

The PVA lacked jurisdiction to decide on the economic provisions and the SONA bonus issue.
The adjustments were contrary to EO No. 7 and RA No. 10149.

The CA, on July 21, 2017, annulled the PVA ruling for lack of jurisdiction and held that:

The new benefits and SONA bonus contravened existing laws.
There was no legal basis for the issuance of a writ of execution or garnishment against SHFC’s public funds.

Whether the PVA had the authority to decide on the interpretation and implementation of the economic provisions specified in the CBAs.
Whether the PVA could rule on the characterization of the SONA bonus as a regular benefit, given statutory limitations and the governing EO.

Whether implementing the additional benefits and increases under the 2011 and 2013 CBAs was permissible despite the moratorium imposed by EO No. 7 and the regulatory framework under RA No. 10149.
Whether the SOHEAI’s claim of non-diminution of benefits could override the adjustments mandated by governmental policies.

Whether the SONA bonus, given its history and payment as a gratuity, had matured into an enforceable regular benefit.
Whether any legal basis existed to sustain a claim for the ongoing payment of the SONA bonus to SHFC employees.

Whether the issuance of a writ of execution and subsequent garnishment of SHFC’s public funds was proper under existing legal constraints.
The role of administrative remedies and the requirement for Commission on Audit (COA) approval in money claims against the government.