Case Summary (G.R. No. L-16982)
Petitioner
Coca-Cola Bottlers Philippines, Inc., employer and appellant before the Supreme Court.
Respondent
Royal Plant Workers Union, the union representing bottling operators and petitioner before the Court of Appeals.
Key Dates
• 1974: Chairs provided to Line 2 operators by request.
• 1988: Chairs extended to Line 1 operators.
• September 2008: National directive removes all operators’ chairs.
• July 16 2009: Union serves Notice to Arbitrate.
• October 1 2009: Submission Agreement executed; single issue set for arbitration.
• June 11 2010: Voluntary Arbitration Panel orders restoration of chairs.
• May 24 2011: Court of Appeals nullifies arbitration award, sustains removal.
• April 15 2013: Supreme Court decision.
Applicable Law
• 1987 Constitution (as decision post-1990).
• Labor Code of the Philippines: Article 3 (state policy on just and humane work conditions), Article 100 (non-diminution of benefits), Article 132 (facilities for women).
• 1997 Rules of Civil Procedure, Rule 43 on petitions for review.
• Collective Bargaining Agreement (CBA) between CCBPI and ROPWU.
• Established jurisprudence on management prerogative and appellate remedies.
Factual Background
For decades, CCBPI provided chairs to bottling operators as a voluntary practice. In 2006, it launched an “Operate, Maintain, Clean” program requiring constant movement. Pursuant to a national directive and safety rationale—to prevent sleeping on the job and improve supervision—CCBPI removed the chairs in September 2008. It compensated by shortening work‐rotation intervals from 2½ to 1½ hours and extending breaks to 30 minutes.
Arbitration Proceedings
After exhausting the CBA’s grievance machinery and failing mediation before the NCMB, ROPWU invoked voluntary arbitration. Both parties appointed an arbitration committee, framed the sole issue as the validity of chair removal, and submitted position papers.
Ruling of the Arbitration Committee
On June 11 2010, the panel found the removal invalid as:
• The long-standing provision of chairs constituted a favorable company practice ripened into a vested benefit under Article 100 of the Labor Code.
• CCBPI failed to prove any actual incidents of operators sleeping on duty or related injuries.
• Line efficiency depends on multiple factors, not solely on chair removal.
It ordered CCBPI to restore the chairs.
Court of Appeals Decision
On May 24 2011, the CA granted CCBPI’s petition for review under Rule 43, set aside the arbitration award, and sustained chair removal as a valid exercise of management prerogative, highlighting that:
• Management may control and manage its enterprise, including working methods, subject to good faith and employees’ rights.
• Removal served legitimate safety and efficiency objectives under the “Operate, Maintain, Clean” program.
• The CBA did not expressly guarantee chair provision; any unenumerated benefit remained purely voluntary per its Article I, Section 2.
• Article 100’s non-diminution rule applies to monetary benefits or their equivalents, not to voluntary practices like chairs.
Issues Presented to the Supreme Court
- Whether a petition for review under Rule 43 is the proper remedy to assail an arbitration panel’s decision.
- Whether CCBPI validly exercised its management prerogative in removing the operators’ chairs.
Proper Appellate Remedy
The Court reaffirmed that awards of voluntary arbitrators are appealable to the Court of Appeals via petition for review under Rule 43, consistent with Luzon Development Bank, Alcantara, Jr., and subsequent jurisprudence. Rule 43’s scope explicitly includes voluntary arbitrators, and Section 2’s exclusion of Labor Code cases does not encompass voluntary arbitration awards.
Validity of Management Prerogative
Under the 1987 Constitution and the Labor Code, management retains discretion over work assignments and methods,
Case Syllabus (G.R. No. L-16982)
Facts and Procedural Antecedents
- Coca-Cola Bottlers Philippines, Inc. (CCBPI) operates nationwide bottling plants, including its Cebu City facility, manufacturing, selling, and distributing soft-drink products.
- Cebu plant employs 20 operators on Bottling Line 1 and 12–14 operators on Bottling Line 2; all are male members of the Royal Plant Workers Union (ROPWU).
- Operators work two shifts (8 a.m.–5 p.m. and 5 p.m.–end of production), with overtime pay for hours beyond eight; each shift follows a rotation of work and breaks (pre-September 2008: 2½ hours work/30 minutes break; post-September 2008: 1½ hours work/30 minutes break).
- Chairs were provided to Line 2 operators in 1974 and to Line 1 operators in 1988 upon employee request, becoming a long-standing company practice.
- In September 2008, CCBPI issued a national directive—aligned with its “I Operate, I Maintain, I Clean” program—removing all bottling-line chairs to compel constant operator movement, ensure machinery upkeep, prevent sleeping on the job, and enhance safety and operational efficiency.
- The Union filed a grievance under the Collective Bargaining Agreement (CBA) in November 2008; after deadlock and failed NCMB conciliation, it served a Notice to Arbitrate (July 16, 2009).
- Parties formed a Voluntary Arbitration Committee on October 1, 2009 via a Submission Agreement; the sole arbitral issue was the validity of removing operators’ chairs.
Arbitration Committee Decision
- On June 11, 2010, the Arbitration Committee ruled in favor of ROPWU, declaring the chair removal invalid and ordering CCBPI to restore the chairs.
- It held that 20– and 34-year practices (Line 1 and Line 2, respectively) ripened into non-diminishable benefits under Article 100 of the Labor Code.
- The Committee found CCBPI’s justifications unsupported—no evidence of operators sleeping on duty or related accidents over decades of chair usage—and questioned the sudden safety motive after years of riskless operation.
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