Case Digest (G.R. No. 181806) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Wesleyan University–Philippines vs. Wesleyan University–Philippines Faculty and Staff Association (G.R. No. 181806, March 12, 2014), petitioner Wesleyan University–Philippines (WU-P), a non-stock, non-profit educational institution, and respondent Wesleyan University–Philippines Faculty and Staff Association (WU-PFSA), the sole and exclusive bargaining agent of all rank-and-file faculty and staff, executed a five-year Collective Bargaining Agreement (CBA) effective June 1, 2003 to May 31, 2008. On August 16, 2005, WU-P’s President Atty. Guillermo T. Maglaya issued a Memorandum unilaterally revising the accrual and commutation of vacation and sick leave credits. Respondent formally objected on August 25, 2005, citing Sections 1 and 2, Article XII of the CBA, which guaranteed fifteen days of paid vacation and sick leave annually and automatic commutation of unused vacation leave after the second year of service. In a February 8, 2006 Labor Management Committee meeting, petition Case Digest (G.R. No. 181806) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and CBA
- Petitioner Wesleyan University-Philippines is a non-stock, non-profit educational institution.
- Respondent Wesleyan University-Philippines Faculty and Staff Association is the sole and exclusive bargaining agent of rank-and-file faculty and staff.
- Collective Bargaining Agreement and Memorandum
- December 2003: parties signed a five-year CBA effective June 1, 2003 to May 31, 2008, covering vacation leave, sick leave, separation and retirement benefits.
- August 16, 2005: petitioner issued a Memorandum revising guidelines on vacation and sick leave credits (earned at 1.25 days/month, not automatic) and vacation leave commutation (monetized after two years).
- Grievance and Arbitration Proceedings
- August 25, 2005: respondent’s letter rejected unilateral changes as violative of Sections 1 and 2, Article XII of the CBA (15 days VL/SL annually and commutation rules).
- February 8, 2006: Labor Management Committee meeting; petitioner advised respondent to file grievance and announced a “one-retirement policy.”
- November 2, 2006: Voluntary Arbitrator’s Decision declared the Memorandum and one-retirement policy contrary to law, ordered reinstatement of previous leave scheme and dual retirement benefits under CBA and PERAA Plan.
- Court of Appeals Proceedings
- September 25, 2007: CA Decision affirmed the Voluntary Arbitrator for lack of consent to unilateral amendments.
- February 5, 2008: CA Resolution denied petitioner’s motion for reconsideration.
Issues:
- Whether the CA gravely erred in finding respondent’s affidavits as substantial evidence of a long-standing two-retirement-benefits practice.
- Whether the CA gravely erred in ruling that a consistent company practice of granting two retirement benefits had been established.
- Whether the CA gravely erred in placing on petitioner the burden to prove the absence of any Board resolution authorizing dual retirement benefits.
- Whether the CA gravely erred in revoking the August 16, 2005 Memorandum as contrary to existing CBA policy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)