Case Summary (G.R. No. 188066)
Procedural History
The petitioner filed a petition for certiorari to contest the resolution dated October 10, 1991, of the National Labor Relations Commission (NLRC) and the subsequent resolution on March 11, 1993, which denied the petitioner’s motion for reconsideration. The case originated from NLRC NCR Case No. 000977-90 initiated by the union on February 9, 1990, due to the impasse in collective bargaining, leading to compulsory arbitration.
Labor Arbiter's Decision
On September 28, 1990, after hearings and deliberations, the labor arbiter issued a decision directing the parties to formalize a new five-year CBA retroactive to the expiration of the old CBA. The labor arbiter’s decision included provisions increasing commission rates, salaries, and wages, as well as the awarding of a signing bonus. This decision was contested by the petitioner, leading to its appeal before the NLRC.
Issues Presented
The petitioner raised multiple issues on appeal: the NLRC's alleged error in affirming the labor arbiter’s decision concerning salary increases, the grant of a signing bonus, the retroactivity of the new CBA to the old CBA's expiration, and questioning the jurisdiction of the labor arbiter, among others.
Jurisdiction of the Labor Arbiter
Despite initially consenting to the arbitration process, the petitioner later contested the jurisdiction of the labor arbiter. The Supreme Court ruled that by agreeing to submit the matter for arbitration, the arbitration was effectively voluntary, despite initial framing as compulsory arbitration. The new provisions of the Labor Code, per R.A. No. 6715, emphasized voluntary arbitration when parties reach a stalemate in negotiations.
Factual Findings
The Court affirmed the labor arbiter's and NLRC's factual findings, emphasizing the substantial evidence standard required in administrative proceedings. The argument by the petitioner that the NLRC failed to adequately consider evidence presented was rejected. The arbitral findings concerning the financial stability of the company and the reasonableness of wage increases suggested adequate assessment of the economic positions of both parties.
Retroactivity of the Collective Bargaining Agreement
The petitioner claimed that the new CBA could not retroactively apply to March 15, 1989, due to provisions outlined in Article 253-A of the Labor Code regarding post-expiration agreements. The Court clarified that the CBA in question emerged as part of an arbitral award rather than a mutual agreement, thus permitting retroactive effect as stipu
...continue readingCase Syllabus (G.R. No. 188066)
Case Background
- The case involves a petition for certiorari filed by Manila Central Line Corporation against the Manila Central Line Free Workers Union-National Federation of Labor and the National Labor Relations Commission (NLRC).
- The petition seeks to annul the NLRC's resolution dated October 10, 1991, which dismissed the appeal of Manila Central Line Corporation from the order of Labor Arbiter Donato G. Quinto, Jr., in NLRC NCR Case No. 02-00813-90, along with the NLRC's resolution dated March 11, 1993, denying reconsideration.
- The dispute arose from a collective bargaining deadlock after the expiration of their collective bargaining agreement (CBA) on March 15, 1989.
Procedural History
- After failing to reach a new agreement, the union sought assistance from the National Conciliation and Mediation Board (NCMB) on October 30, 1989.
- The union subsequently filed a Petition for Compulsory Arbitration on February 9, 1990, after conciliation efforts were unsuccessful.
- At the initial hearing, both parties expressed their readiness to submit the case for compulsory arbitration, leading to the submission of their respective position papers and proposals.
Labor Arbiter's Decision
- On September 28, 1990, the labor arbiter issued a decision mandating the execution of a new five-year CBA retroactive to the expiration date of the previous agreement.
- Key provisions included:
- An increase in commission rates and incentive pays.
- A P500 signing bonus for the employees.
- Retroactive effectivity of the new CBA to March 15, 1989.