Case Digest (G.R. No. 76883)
Facts:
Vassar Industries, Inc. v. Vassar Industries Employees Union (VIEU) and/or Danilo Ordonez, G.R. No. 76883, September 07, 1989, First Division, Narvasa, J., writing for the Court.
The parties were Vassar Industries, Inc. (petitioner) and the Vassar Industries Employees Union (VIEU), represented by Danilo Ordonez (respondents). The dispute arose from a collective bargaining agreement (CBA) executed October 1, 1978, with a three-year term that provided, among other things, a general wage increase of P15.00 per month and required re‑negotiation of salary increases in the agreement's second and third years.
During the 1980 renegotiation (the third year of the CBA) the parties failed to agree on the wage increase and submitted the issue to compulsory arbitration before Labor Arbiter V. G. Son. An amicable settlement was reached and embodied in an order dated March 6, 1981, awarding a salary increase of P1.25 per day for the third year of the CBA (October 1, 1980 to September 30, 1981), effective October 1, 1980.
On March 26, 1981, Wage Order No. 1 was promulgated under the President’s stand‑by legislative authority increasing the mandatory emergency cost‑of‑living allowance to P2.00 per day and providing that "all increases in wages granted unilaterally or by CBA shall be credited ... provided such increases were granted between January 1, 1981 and March 22, 1981." On April 10, 1981 the National Wages Council issued implementing rules (including Sec. 8), which expressly excluded anniversary increases under CBAs from being creditable.
Relying on the Wage Order and its implementing rules, Vassar paid workers an additional P0.75 per day commencing March 22, 1981 (treating the earlier P1.25 as creditable). The Union disagreed, filed NLRC Case No. AB‑IV‑10‑528‑81 to compel Vassar to pay both the P2.00 allowance and the P1.25 CBA increase. The Labor Arbiter ruled for the Union; the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s judgment by decision promulgated June 9, 1986, with a majority (Chairman and six members) for the Union and three commissioners dissenting.
Vassar filed a petition for certiorari with the Supreme Court on January 6, 1987, alleging grave abuse of discretion by the NLRC and contending that the P1.25 increase was creditable under Wage Order No. 1 and controlling jurisprudence (citing Dole Philippines, Inc. v. Leogardo, Jr., National Federation of Sugar Workers v. Ovejera, and Brokenshire Memorial Hospital v. NLRC). A verified supplemental petition alleged factory closure at Sta. Rosa and that many employees had been paid and executed quitclaims while the case was on appeal. The Solicitor General and the Union argued the opposite position, treating the P1.25 as an annive...(Pro-only)
Issues:
- Did the National Labor Relations Commission commit grave abuse of discretion in affirming the Labor Arbiter's decision?
- May an implementing rule (Sec. 8 of the National Wages Council rules) limit or modify the clear provision of Wage Order No. 1 that permits the crediting of all increases in wages granted unilaterally or by CBA between January 1 and March 22, 1981, and is the P1.25 per day increase granted by Vassar creditable against the ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)