Case Digest (G.R. No. 220383)
Facts:
In 2007 and 2008, Universal Robina Corporation, Sugar Division - Southern Negros Development Corporation offered P16.00/day wage increases each year conditioned on employees signing waivers postponing the effect of any subsequent Collective Bargaining Agreement; several members of SONEDCO Workers Free Labor Union refused to sign and thus did not receive the increases and filed an unfair labor practice complaint on July 2, 2009.
The NLRC and Court of Appeals ordered payment of the 2007 and 2008 increases but denied relief for 2009; this Court found URC-SONEDCO guilty of unfair labor practice in its October 5, 2016 Decision, granted the 2007 and 2008 increases and damages, and on reconsideration modified the disposition to incorporate a P32.00/day wage increase for petitioners from January 1, 2009 to present and to award attorney’s fees of ten percent of the total award.
Issues:
- Should the continuing wage increase of P32.00/day from January 1, 2009 to present be awarded to the petitioners?
- Are attorney’s fees recoverable in this case?
Ruling:
The Court granted the Motion for Partial Reconsideration and ordered respondent to pay the P16.00/day increases for 2007 and 2008 as previously held and to incorporate a P32.00/day wage increase to the petitioners’ wages from January 1, 2009 to present. The Court also awarded moral and exemplary damages as before and assessed attorney’s fees equal to ten percent of the total award.
Ratio:
The Court reasoned that respondent induced waiver of collective bargaining rights by granting and integrating the P32.00/day increases to employees who signed the waivers, constituting an unfair labor practice and resulting in ongoing discrimination against petitioners. Granting the continuing wage increase remedied the consequences of that unlawful discrimination and was not an impermissible attempt to alter the 2009 Collective Bargaining Agreement, but rather a corrective measure to eliminate differential treatment caused by respondent’s prior misconduct. The award of attorney’s fees followed from the imposition of exemplary damages and the Court’s equitable power to make plaintiffs whole, consistent with Civil Code, art. 2208.
Doctrine:
- A Collective Bargaining Agreement ordinarily governs employer-employee relations and benefits not included therein are not demandable.
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