Case Summary (G.R. No. 230919)
Applicable Law
This decision is anchored on the 1987 Philippine Constitution and the Labor Code of the Philippines, particularly Article 245, which addresses the eligibility of managerial employees to join labor organizations.
Factual Background
Huliganga was employed by SITA on April 16, 1980, and served in various capacities until his retirement. Upon leaving, he received retirement benefits calculated based on a coefficient of 1.5 months of basic pay for each year of service, amounting to P7,495,102.84. However, he alleged underpayment and filed a complaint on January 27, 2009, claiming that the correct coefficient should have been 2 months per year, as stipulated in a 2005-2010 Collective Bargaining Agreement (CBA).
Claims and Counterarguments
In his complaint, Huliganga contended that the company consistently adopted the new economic benefits from the CBA as binding amendments to their Employee Regulations Manual. He claimed underpayment not only for retirement benefits but also for wages, vacation and sick leaves, and sought moral damages and attorney's fees. The petitioners rebutted by asserting that Huliganga had received full benefits, denied the existence of an employer-employee relationship with EQUANT and SITA, INC., and argued against claims for damages due to alleged deficiencies.
Labor Arbiter and NLRC Findings
The Labor Arbiter dismissed Huliganga's complaint, stating it lacked merit. This was affirmed by the National Labor Relations Commission (NLRC), which upheld the dismissal, stating there was no employer-employee relationship between Huliganga and the responding entities and that he had received his entitled benefits.
Court of Appeals Ruling
However, on March 21, 2014, the Court of Appeals partially granted Huliganga's petition, ruling that he was entitled to an additional P2,645,175.87 in retirement benefits, indicating that the practices surrounding the CBA had become established company practice. The CA found that at the time of Huliganga's retirement, the applicable CBA provided a coefficient of 2 months but disallowed claims against SITA, INC. and EQUANT.
Petitioners' Argument and Legal Review
The petitioners challenged the CA's conclusions, arguing that the retirement benefits differed for managerial versus rank-and-file employees and claimed a lack of factual basis for extending CBA benefits to Huliganga. The Supreme Court, however, observed that the CA's findings contradicted those of the Labor Arbiter and the NLRC.
Supreme Court Findings
The Supreme Court stated that managerial employees like Huliganga are not entitled to benefits under the CBA unless an establish
...continue readingCase Syllabus (G.R. No. 230919)
Case Overview
- This case is a Petition for Review on Certiorari filed by petitioners Societe Internationale de Telecommunications Aeronautiques (SITA), SITA Information Networking Computing B.V. (SITA, INC.), Equant Services, Inc. (EQUANT), and Lee Chee Wee against respondent Theodore L. Huliganga.
- The petition seeks to reverse and set aside the Decision dated March 21, 2014, and the Resolution dated October 7, 2014, both rendered by the Court of Appeals (CA).
- The CA had granted Huliganga the amount of Php 2,645,175.87 as deficiency in his retirement benefit.
Facts of the Case
- Huliganga was employed by SITA starting April 16, 1980, and eventually became the Country Operating Officer before retiring on December 31, 2008.
- Upon retirement, he received Php 7,495,102.84 as retirement benefits, calculated at 1.5 months of basic pay for each year of service.
- On January 27, 2009, Huliganga filed a complaint against SITA and its affiliates for unfair labor practices and underpayment of various benefits, arguing that he should be entitled to 2 months of pay per year of service as per the 2005-2010 Collective Bargaining Agreement (CBA).
- The petitioners contended that Huliganga had already received full benefits and denied any employer-employee relationship with SITA, INC. and EQUANT.
Labor Arbiter's Decision
- On September 29, 2009, the