Case Summary (G.R. No. 81144)
Collective Bargaining Agreement
The issue centers on the interpretation and enforcement of a collective bargaining agreement (CBA) entered into in 1983, which stipulated a salary scale for faculty members for the period covering 1983 to 1986. Article IV of the CBA distinctly outlines the salary structure based on years of service, and it was intended to provide better economic conditions for the college's instructors.
Government Mandated Wage Increases
Throughout the duration of the CBA, several presidential decrees and wage orders were enacted which increased minimum wages and mandated additional allowances for workers. While the union acknowledged that its members received these legally mandated increases, there was a contention that these increases did not fulfill the college's obligation to adhere to the CBA's prescribed salary scale.
Filing for a Notice of Strike
Following the union's discovery in 1987 that the petitioner had not implemented the salary scale as set in the CBA, the union filed a notice of strike on March 27, 1987, citing unfair labor practices. The Department of Labor and Employment intervened, leading to ongoing legal discussions about the nature of compliance with both statutory wage provisions and contractual obligations inherent in the CBA.
Findings of the Secretary of Labor
The Secretary of Labor agreed with earlier findings by the Regional Director that while the petitioner complied with legal wage mandates, this did not fulfill the contractual obligations under the CBA. The Secretary determined that the enforcement of the CBA was mandatory and non-compliance constituted an unfair labor practice, leading to an order requiring the college to adhere to the CBA.
Petitioner’s Motion for Reconsideration
After the Secretary ordered the college to comply with the CBA, Meycauayan College filed a motion for reconsideration, asserting that the Secretary exceeded his authority by imposing obligations retroactively beyond legal time constraints. This motion was denied, prompting the current petition before the court for certiorari, seeking to annul the Secretary's order.
Legal Framework and Distinction Between Law and CBA
The court emphasized the binding nature of collective bargaining agreements and the clear distinction between legal obligations arising from statutes and the terms set forth in a CBA. It ruled that the petitioner could not assert that compliance with legislative wage increases absolved it of duty under the CBA.
Interrelationship Between Salary Increases and CBA Obligations
The court underscored the intention of both parties in entering into the CBA was to improve the economic status of the teachers, thus salary increases, whether legislated or agreed upon in the CBA, serve the same purpose. A refusal to fulfill the CBA's terms would amount to an unfair labor practice, underscoring the protective labor policy in the Philippines.
Applicability of the One-Year Period for Unfair Labor Practices
The petitioner raised the argument concerning the applicability of the one-year prescriptive period for filing unfair labor practice claims, suggesting it should bar clai
...continue readingCase Syllabus (G.R. No. 81144)
Background of the Case
- The case involves a petition for certiorari concerning salary increases for employees due to presidential decrees and wage orders.
- The central issue is whether these increases, which exceed the salary scale agreed upon in a collective bargaining agreement (CBA), prevent employees from claiming the difference in salaries.
- Meycauayan College, a private educational institution in Bulacan, recognized the Meycauayan College Faculty and Personnel Association (MCFPA) as its employees' union on January 16, 1987.
Collective Bargaining Agreement
- A CBA was entered into on July 17, 1983, covering the period from 1983 to 1986.
- Article IV of the CBA outlined a detailed salary scale based on the length of service of teachers, specifying rates from P51.50 to P70.00 depending on years of service.
- Various presidential decrees and wage orders were already in effect during the execution of the CBA, mandating increases in minimum wages and allowances.
Discovery of Non-Compliance
- In 1987, after a change in union leadership, the new president discovered that the salary scale provisions of the CBA had not been implemented.
- On March 27, 1987, the union filed a notice of strike with the Department of Labor and Employment (DOLE) citing unfair labor practices and violations of the CBA.
Labor Dispute Proceedings
- The Secretary of Labor assumed jurisdiction over the dispute and ordered an investigation by t