Case Summary (G.R. No. 195297)
Petitioner
A domestic corporation manufacturing and selling non-alcoholic beverages, with a Collective Bargaining Agreement (CBA) providing for optional Saturday work based on operational necessity.
Respondent
A labor union representing CCBPI’s daily-paid workers, contending that Saturday work is a mandatory component of the normal work week under the CBA and that its unilateral removal violated the non-diminution rule.
Key Dates
– July 1–2, 2005: CCBPI notifies ICCPELU of discontinuance of scheduled Saturday work.
– September 7, 2006: Panel of Arbitrators rules for CCBPI.
– October 24, 2006: Panel denies ICCPELU’s motion for reconsideration.
– June 23, 2010: CA reverses the Panel and orders reinstatement of Saturday work and back wages.
– October 19, 2010: CA denies CCBPI’s motion for reconsideration.
– December 5, 2018: Supreme Court renders final decision under G.R. No. 195297.
Applicable Law
– 1987 Philippine Constitution (Article XIII, Section 3).
– Labor Code of the Philippines: Articles 83 (normal hours), 87 (overtime work), 100 (non-diminution of benefits).
– CBA provisions: Article 10, Sections 1–2 (work week and schedule changes); Article 11, Section 1(c) (Saturday as premium day with management option to schedule work); Article 11, Section 2(c) (premium pay on Saturday).
Antecedent Facts
CCBPI’s CBA defined a normal work week as Monday–Friday (8 hours/day) plus Saturday (4 hours), with management having the option to schedule Saturday work based on operational necessity. In July 2005 CCBPI ceased regular Saturday scheduling to reduce expenses. ICCPELU filed a grievance, elevated it to voluntary arbitration, and disputed CCBPI’s prerogative to eliminate Saturday work.
Procedural History
The three-member Panel of Arbitrators upheld CCBPI’s right not to schedule Saturday work and ruled that employees were not entitled to basic pay when not reporting on Saturdays. ICCPELU appealed to the CA under Rule 43. The CA reversed, holding Saturday work mandatory and ordering CCBPI to resume the 4-hour Saturday shift and pay back wages plus premiums. CCBPI then sought certiorari relief before the Supreme Court under Rule 45.
Issues Presented
- Whether the CBA mandates compulsory scheduling of Saturday work for CCBPI’s employees.
- Whether the long-standing practice of Saturday work ripened into a benefit protected against diminution under Article 100 of the Labor Code, entitling employees to back wages.
Petitioner's Arguments
– The CBA clearly grants management the optional prerogative to schedule Saturday work; the word “work” refers to the day itself, not merely its hours.
– Premium pay for Saturdays confirms that Saturday work is not a regular entitlement but compensation for additional services.
– Past cases hold that overtime and additional hours do not constitute “benefits” under the non-diminution rule.
– Reinstating unworked Saturdays and paying wages despite no work breaches the “no work, no pay” principle.
Respondent's Arguments
– Article 10, Section 1 unequivocally includes Saturday as part of the normal work week.
– Ambiguities in the CBA must be construed in favor of labor.
– The option to “schedule work” does not authorize unilateral elimination of Saturday work.
– A long-standing practice of Saturday work created a protected company practice; its removal diminished employee benefits.
Court’s Analysis: Interpretation of the CBA on Saturday Work
The Supreme Court applied the settled rule that clear and unambiguous contract terms control. Article 11, Section 1(c) grants management the option “to schedule work on Saturdays on the basis of operational necessity.” If the intention were only to modify working hours, the parties would have said “working hours,” as they did elsewhere in Article 10, Section 2. The phrase “required to work on Saturday” in Article 10, Section 1 would be surplusage if Saturday work were mandatory. The plain meaning confirms that management may require Saturday work when necessary and may refrain when there is no operational exigency.
Court’s Analysis: Company Practice and Diminution of Benefits
The Court distinguished Saturday work from statutory overtime, which is work in excess of eight hours a day. Here, the issue is work within four of those hours on a separate day. The protected “benefit” under Article 100 is the premium pay (50% of t
...continue readingCase Syllabus (G.R. No. 195297)
Procedural History
- Petition for Review on Certiorari filed by Coca-Cola Bottlers Philippines, Inc. (CCBPI) under Rule 45 of the Rules of Court.
- Challenged Decision dated September 7, 2006 of the NCMB Regional Branch No. 6, Iloilo City; reversed by the Court of Appeals (CA) in its Decision dated June 23, 2010 and Resolution dated October 19, 2010.
- CCBPI’s Motion for Reconsideration denied by CA; CCBPI secured extension to file Petition for Certiorari with the Supreme Court.
- Respondent Iloilo Coca-Cola Plant Employees Labor Union (ICCPELU) filed Comment; CCBPI filed Reply; case submitted for resolution.
Antecedent Facts
- CCBPI operates a beverage manufacturing plant in Ungka, Pavia, Iloilo City; employs daily-paid route drivers and helpers represented by ICCPELU.
- Collective Bargaining Agreement (CBA) provides normal work week: Monday–Friday (8 hrs/day) and Saturday (4 hrs), with management having the option to schedule Saturday work based on operational necessity.
- On July 1, 2005, CCBPI announced cessation of regular Saturday scheduling effective July 2, 2005 to reduce operating expenses amid anticipated revenue decline.
- ICCPELU opposed the proposal, filed written grievance citing violation of Article 10 Section 1, Article 11 Section 1(c) of the CBA; requested meetings and arbitration after CCBPI reiterated its operational-necessity prerogative.
- On June 9, 2006, parties submitted to voluntary arbitration before a three-member panel of NCMB arbitrators.
NCMB Panel Ruling
- Issue 1: Employees not entitled to basic pay for Saturdays if they did not report to work (CBA Sections I–10; II–1(c), 3(c)).
- Issue 2: CCBPI cannot be compelled to provide work on Saturdays under the CBA for lack of legal and factual basis.
- Panel denied ICCPELU’s Motion for Reconsideration on October 24, 2006.
Court of Appeals Decision
- Reversed and set aside NCMB Panel’s Decision and Order.
- Ordered CCBPI to:
• C