Facts:
On October 5, 2016, the Second Division rendered judgment in G.R. No. 220383 between
SONEDCO Workers Free Labor Union (SWOFLU) and its members as petitioners and
Universal Robina Corporation, Sugar Division - Southern Negros Development Corporation (URC-SONEDCO) as respondent. On May 6, 2002 URC-SONEDCO and
Philippine Agricultural Commercial and Industrial Workers Union (PACIWU-TUCP) executed a Collective Bargaining Agreement (2002 CBA) effective January 1, 2002 to December 31, 2006, and on May 17, 2002 a certification election was conducted in which SWOFLU prevailed; Mediator-Arbiter Romulo Sumalinog certified SWOFLU on July 8, 2002 and the Labor Secretary affirmed that certification on December 27, 2002, final on April 15, 2003, a result later upheld by the Court on July 11, 2007. Despite SWOFLU’s status as exclusive bargaining representative, URC-SONEDCO repeatedly refused to negotiate a new CBA and instead, after the 2002 CBA expired on December 31, 2006, offered economic benefits for 2007 and 2008 conditioned upon employees’ signing acknowledgment receipts/waivers (the 2007 and 2008 waivers) that effectively postponed the effectiveness of any subsequently negotiated CBA to the following year; several union members refused to sign and thus did not receive the benefits. SWOFLU and the refusing members filed a complaint for unfair labor practices on July 2, 2009. The Labor Arbiter found no unfair labor practice but ordered payment of the withheld benefits; the National Labor Relations Commission affirmed the Labor Arbiter’s disposition and likewise granted the withheld benefits; the Court of Appeals dismissed the petition for certiorari filed by petitioners; petitioners then brought this Rule 45 petition to the Supreme Court, which required respondent’s comment and thereafter rendered the challenged decision.
Issues:
Did URC-SONEDCO commit an
unfair labor practice by refusing to bargain and by conditioning company-granted benefits on waivers that foreclosed negotiation for 2007 and 2008?; Are petitioners who refused to sign the 2007 and 2008 waivers entitled to the wage increase and other economic benefits for 2007 and 2008 as continuing employee benefits notwithstanding the 2009 Collective Bargaining Agreement?; Is URC-SONEDCO liable to pay damages for its conduct?
Ruling:
Ratio:
Doctrine: