G.R. No. 220383 - SONEDCO Workers Free Labor Union vs. Universal Robina Corp.

The case involves petitioners represented by the SONEDCO Workers Free Labor Union (SWOFLU) and the respondent Universal Robina Corporation – Sugar Division (URC-SONEDCO), later known as Southern Negros Development Corporation.
Initially, URC-SONEDCO entered into a 2002 Collective Bargaining Agreement (CBA) with PACIWU-TUCP covering January 1, 2002 to December 31, 2006, which provided for a wage increase of P14.00/day for 2002 and P12.00/day for subsequent years up to 2006.

Shortly after the 2002 CBA was signed, a certification election was held on May 17, 2002 wherein SWOFLU won, replacing PACIWU-TUCP as the exclusive bargaining agent.
Despite disputes regarding the validity of the election raised by PACIWU-TUCP before the Department of Labor and Employment (DOLE) and later in quasi-judicial proceedings, the certification was ultimately upheld by both the DOLE and the courts, confirming SWOFLU as the bargaining agent.

As the 2002 CBA was in force and then expired on December 31, 2006, URC-SONEDCO consistently refused to negotiate a new agreement with SWOFLU.
Even though SWOFLU petitioned for a new certification election in view of the approaching expiration, respondent maintained reliance on the prior 2002 CBA, claiming it still governed negotiations due to its earlier formation with PACIWU-TUCP.

With no new CBA in place, on August 28, 2007, URC-SONEDCO offered economic benefits including a wage increase of P16.00/day, group life insurance, emergency leave, and a cash loan.
The company required employees desiring these benefits to sign a waiver (the “2007 waiver”) stating that if a subsequent CBA was negotiated, its effect would only commence on January 1, 2008.
A similar arrangement was made in 2008 with another waiver (the “2008 waiver”), wherein benefits were again provided on the condition of a waiver that deferred the effective date of any new CBA to January 1, 2009.
Several union members refused to sign these waivers, thereby being excluded from receiving the offered benefits.

In 2008, after a second certification election, SWOFLU successfully negotiated a new CBA covering January 1, 2009 to December 31, 2013.
SWOFLU, along with the members who refused to sign the waivers, filed a complaint for unfair labor practices against URC-SONEDCO, arguing that the waiver strategy undermined their right to self-organization and collective bargaining.
Although the Labor Arbiter and the National Labor Relations Commission (NLRC) initially found that the imposition of the waivers did not constitute an unfair labor practice, the petitioners maintained that the employer’s conduct amounted to bad faith bargaining and intentional undermining of the union’s power.

Petitioners alleged that URC-SONEDCO’s repeated refusal to negotiate—including ignoring written proposals and delaying negotiations—constituted unfair labor practice under Article 259 of the Labor Code, particularly paragraph (g) regarding the duty to bargain collectively.
They further contended that the conditional wage increase and the waiver requirement were designed as economic incentives to forestall collective bargaining, thereby restricting their right to secure a more favorable wage increase (they claimed a P50.00/day increase was warranted).
Petitioners also argued that since the new CBA did not include the benefits for 2007 and 2008, the wage increases for those years should continue as a continuing benefit from the previous offers.

Whether URC-SONEDCO committed an unfair labor practice by refusing to bargain in good faith with the SWOFLU.

Did the employer’s insistence on waivers before releasing the wage increases and other benefits amount to interference with the employees’ right to self-organization and collective bargaining?
Whether the totality of respondent’s conduct, including reliance on a now-outdated 2002 CBA, violated its duty to bargain collectively.

Whether the employees who refused to sign the 2007 and 2008 waivers are entitled to the wage increases and other economic benefits for those years despite the entry into the 2009 CBA.

Should the wage increase acts as a continuing benefit given that the 2009 CBA did not retroactively cover 2007 and 2008?

Whether URC-SONEDCO should be held liable for moral and exemplary damages due to its refusal to negotiate and its overall conduct in dealing with the union.