Case Summary (G.R. No. 205693)
Background and Collective Bargaining Agreement
On December 24, 2008, the SHFC and SOHEAI entered into a CBA, which was subsequently renegotiated on December 22, 2011, to address economic provisions and introduce various employee benefits. Adjustments included increasing the number of emergency leaves, enhancing insurance and health coverage, as well as transportation allowances. Additional provisions covered funeral assistance, children’s allowances, and a new anniversary bonus amounting to P3,000.
Government Commission Intervention
On January 17, 2012, the Governance Commission for GOCCs informed SHFC that it lacked authority to negotiate the new benefits due to a moratorium established by Executive Order (EO) No. 7, which barred increases in salaries, allowances, incentives, and benefits for GOCC employees until presidential approval was obtained. Consequently, SHFC revoked the newly agreed benefits. This decision prompted SOHEAI to argue that the revocation countered the policy against the diminishment of benefits.
Dispute Resolution Attempts
Following the failure to resolve these grievances through internal mechanisms, including preventive mediation with the National Conciliation and Mediation Board, SOHEAI escalated the matter to the Panel of Voluntary Arbitrators (PVA). Meanwhile, a new CBA was executed on December 3, 2013, but SHFC claimed, once again, that the PVA lacked jurisdiction in settling CBA economic provisions due to the prohibitory laws.
Ruling of the Panel of Voluntary Arbitrators
On May 12, 2015, the PVA ruled in favor of SOHEAI, ordering SHFC to comply with the economic provisions of the CBAs and acknowledging the State of the Nation Address (SONA) bonus as a regular benefit. This ruling was subsequently appealed by SHFC to the Court of Appeals (CA), arguing the PVA had overstepped its jurisdiction, particularly given the Governance Commission's directives.
Court of Appeals Decision
On July 21, 2017, the CA annulled the PVA's ruling based on jurisdictional grounds, asserting that the adjustments to benefits were contrary to existing laws mandating presidential approval for such increases. The CA clarified that the SONA bonus was a mere gratuity and not an enforceable obligation.
Supreme Court Final Ruling
Upon review, the Supreme Court granted SHFC’s petition, emphasizing that collective bargaining agreements must not contravene laws such as EO No. 7 and RA No. 10149, which govern the terms applicable to GOCC employment. The SC ruled that the approval to establish benefits rests with the President, thus rendering the new terms of the CB
...continue readingCase Syllabus (G.R. No. 205693)
Case Overview
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals (CA) Decision dated July 21, 2017, in CA-G.R. SP No. 140975.
- The primary issue pertains to the validity of a Collective Bargaining Agreement (CBA) entered into by the Social Housing Finance Corporation (SHFC) and the Social Housing Employees Association, Inc. (SOHEAI).
Background of the Case
- On December 24, 2008, SHFC and SOHEAI entered into a CBA.
- The CBA was renegotiated on December 22, 2011, resulting in various economic provisions including increases in leave benefits, transportation allowances, and introduction of new benefits like an anniversary bonus and increased provident fund contributions.
- On January 17, 2012, the Governance Commission for GOCCs informed SHFC that it lacked authority to negotiate increases in benefits due to Executive Order (EO) No. 7 and Republic Act (RA) No. 10149, which imposed a moratorium on such increases.
Events Following the Revocation of Benefits
- SOHEAI contested the revocation of the new benefits, arguing it violated the policy on non-diminution of benefits and claimed that the annual State of the Nation Address (SONA) bonus had become a regular benefit.
- Following unsuccessful grievance procedures, SOHEAI sought mediation, but mediation failed, leading to arbitration