Case Summary (G.R. No. 85333)
Facts of the Case
On October 12, 1987, the Manila CCBPI Sales Force Union executed a new CBA with Coca-Cola Bottlers, which included a general salary increase in a lump sum. The union president subsequently authorized the company to deduct union dues of P10.00 every payday alongside a 10% special assessment from this lump-sum pay. The purpose of this special assessment, as outlined in a union board resolution, was for various activities beneficial to both union officers and members, including establishing a cooperative and funding consultant services.
Disauthorization of Special Assessment
Initially, 672 union members approved the special assessment. However, later developments saw 355 members withdraw their authorization for the deductions, leading to a total of 528 objectors compared to only 272 supporters. Faced with conflicting claims about the validity of the special assessment, Coca-Cola Bottlers filed for interpleader to resolve the issue within the Bureau of Labor Relations.
Legal Provisions at Issue
The petitioners argued that the deductions violated Article 241(o) and Article 222(b) of the Labor Code, which stipulate that no special assessments or additional fees may be deducted from an employee’s earnings without individual written authorization. The respondents, particularly the Union, contended that the special assessment had been duly authorized according to the provisions of Article 241(n) of the Labor Code, which allows for special assessments if approved by a majority at a general membership meeting.
Med-Arbiter's Initial Ruling
The Med-Arbiter ruled in favor of the petitioners, determining that the Company should remit the withheld amounts directly to the employees. However, this decision was overturned on appeal by the Director of the Bureau of Labor Relations, who held that the Union complied with the requirements necessary for imposing the special assessment.
Petitioners’ Arguments
The petitioners claimed that the Director committed grave abuse of discretion by misapplying Article 241(n) instead of focusing on the more stringent requirements under Articles 241(o) and 222(b). They argued that the Union failed to conduct a valid general membership meeting, did not maintain accurate records of votes during local meetings, and neglected to provide necessary authorizations for deductions.
Court's Findings
Upon thorough examination, the Court agreed with the petitioners that the deductions made by the Union did not meet the legal requirements stipulated in the Labor Code. The Court referenced the decision in Galvadores vs. Trajano, affirming that special assessments cannot be levied without individual written consent from each member. The petitioners' retraction of their authorizations was deemed valid despite the Union's claims to the contrary, emphasizing that the consent of individual members must be strictly adhered to, and shortcuts or insufficient procedures would not suffice.
Violation of Labor Code Provisions
The Court ultimately found that the im
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Case Citation
- Citation: 261 Phil. 856
- Date: February 26, 1990
- Division: First Division
- G.R. No.: 85333
Parties Involved
- Petitioners: Carmelito L. Palacul and others (regular rank-and-file employees and bona fide members of the Union)
- Respondents: Pura Ferrer-Calleja (Director of the Bureau of Labor Relations), Manila CCBPI Sales Force Union, Coca-Cola Bottlers (Philippines), Inc.
Main Issue
- The central issue is whether a labor union can validly deduct a special assessment from the lump-sum pay of its members under a collective bargaining agreement (CBA) despite subsequent disauthorization by a majority of the union members.
Factual Background
- On October 12, 1987, the Union entered into a new CBA with Coca-Cola Bottlers, which included a lump-sum salary increase and a special assessment of 10% on this lump-sum pay.
- The Union obtained authorization through a secret referendum, where 672 members supported the assessment, while 173 opposed it.
- Subsequently, 355 members submitted documents to disauthorize the deductions, resulting in a total of 528 objectors against 272 supporters.
Legal Provisions Cited
- Article 222(b) of the Labor Code: Prohibits charges arising from collective bargaining from being imposed on union members without their individual written authorization.
- Article 241(o) of the Labor Code: States that no special assessments may be deducted without individual written authorization.
- Article 241(n) of the Labor Code: Requires a written resolution approved by a majority of all members during a