Case Summary (G.R. No. 180740)
Facts of the Case
Lepanto Consolidated Mining Company and Lepanto Local Staff Union, representing the staff employees of the mining company, entered into their fourth Collective Bargaining Agreement (CBA) on November 28, 1998. This agreement included provisions for night shift differential pay and longevity pay. On April 23, 2000, the Union filed a complaint alleging the company’s failure to pay the agreed benefits. Both parties failed to amicably settle the dispute and sought resolution from Voluntary Arbitrator Norma B. Advincula.
Ruling of the Voluntary Arbitrator
The Voluntary Arbitrator ruled in favor of the Union, mandating Lepanto Consolidated Mining Company to pay the claimed longevity pay and night shift differential. The Arbitrator clarified that the longevity pay of P30.00 per month should be effective from July 1, 1998, and rejected the company’s argument that the payment should start only on July 1, 1999. Regarding the night shift differential, the Arbitrator confirmed that surface workers after 3:00 p.m. were entitled to an additional pay rate, while also stating that the time used for calculating overtime would not include the night differential.
Ruling of the Court of Appeals
Upon review, the Court of Appeals upheld the Arbitrator's ruling, affirming that the CBA's provisions were unambiguous. The court noted that the petitioner had complied with the CBA by paying the night shift differential to affected employees and rejected the company’s claim that this was due to an error. The court stated that the continuous payment, even after the Arbitrator's decision, indicated the intent to provide the night differential benefits.
Legal Analysis of the Issue
The Supreme Court assessed whether the Court of Appeals erred in affirming the Arbitrator's interpretation regarding entitlement to night shift differential pay. The Court emphasized that the terms of a collective bargaining agreement serve as the law between the parties. Clear language in the CBA indicated entitlement to night shift differential for employees working beyond normal hours. The Court upheld the interpretations of the A
...continue readingCase Syllabus (G.R. No. 180740)
Overview of the Case
- The case involves a petition for review filed by Lepanto Consolidated Mining Company (petitioner) challenging the decisions of the Court of Appeals regarding the interpretation of the 4th Collective Bargaining Agreement (CBA) with the Lepanto Local Staff Union (respondent).
- The case is rooted in the dispute over the payment of night shift differential and longevity pay as stipulated in the 4th CBA.
The Parties Involved
- Petitioner: Lepanto Consolidated Mining Company, a domestic mining corporation.
- Respondent: Lepanto Local Staff Union, the duly certified bargaining agent representing the employees in staff positions of the petitioner.
Antecedent Facts
- On 28 November 1998, the parties entered into their 4th CBA covering the period from 1 July 1998 to 30 June 2000.
- Key Provisions of the 4th CBA:
- Article VIII - Night Shift Differential:
- Section 3 specifies the night differential pay for employees working shifts:
- First Shift (11:00 p.m. to 7:00 a.m.): 20% of the basic rate.
- Third Shift (3:00 p.m. to 11:00 p.m.): 15% of the basic rate.
- No night differential pay for overtime work calculated before the overtime pay is computed.
- Section 3 specifies the night differential pay for employees working shifts:
- Article XII - Longevity Pay:
- Section 9 states a longevity pay of ₱30.00 per month effective from July 1, 1998, and annually thereafter.
- Article VIII - Night Shift Differential:
The Dispute
- On 23 April 2000, the respondent filed a complaint with the National Conciliation and Mediation Board alleging non-payment of the night shift differential and longevity pay.
- After failed attempts at amicable settlement, the parties submitted the dispute to Voluntary Arbitrator Norma B. Advincula.
Ruling of the Voluntary Arbitrator
- On 26 May 2000, the Voluntary Arbitrator ruled in favor of the res