Case Summary (G.R. No. 220383)
Key Dates
- January 1, 2002 - December 31, 2006: Duration of the 2002 Collective Bargaining Agreement (CBA).
- May 17, 2002: Certification election.
- April 15, 2003: Resolution affirming SONEDCO Workers Free Labor Union as the exclusive bargaining representative becomes final.
- December 31, 2006: Expiration of the 2002 CBA.
- August 20, 2008: Certification election where SONEDCO Workers Free Labor Union is declared the winner again.
- October 22, 2015: Petition filed with the Supreme Court.
- January 11, 2016: Court issues a Resolution requiring a comment from URC-SONEDCO.
Applicable Law
Labor Code of the Philippines, specifically Article 259, which pertains to unfair labor practices, and Article 263, explaining the duty to bargain collectively.
Background of the Dispute
After URC-SONEDCO and PACIWU-TUCP (the prior bargaining representative) entered into the 2002 CBA, SONEDCO Workers Free Labor Union emerged victorious in a subsequent certification election, asserting its position as the exclusive bargaining representative. Despite this, URC-SONEDCO repeatedly refused to negotiate a new CBA with SWOFLU, which led to petitions for certification election filed by the union in December 2006, just before the expiration of the 2002 CBA.
Unfair Labor Practice Claim
SWOFLU argued that URC-SONEDCO's refusal to negotiate constituted an unfair labor practice as it restricted the union's bargaining power. The Labor Arbiter initially ruled in URC-SONEDCO’s favor, stating that the employer's offers, such as wage increases and insurance benefits solicited through waivers, were beneficial. However, the Labor Arbiter also ordered payment of those benefits to employees who refused to sign the waivers, recognizing their entitlement despite the employer's actions.
Appeals and Initial Outcomes
An appeal to the National Labor Relations Commission (NLRC) upheld the Labor Arbiter's decision, confirming that the waivers did not confer unfair labor practices as the employer's actions were deemed offers, not coercions. The arguments were further dismissed by the Court of Appeals, which found no grave abuse of discretion regarding the NLRC's findings.
Final Assessment by the Supreme Court
Upon reaching the Supreme Court, a critical assessment was made regarding whether URC-SONEDCO's actions constituted unfair labor practices. The Court highlighted that unfair labor practices encompassed not only interference with self-organization rights but also failure to bargain collectively as mandated. The Court identified that URC-SONEDCO's repeated refusals to engage with SWOFLU, coupled with the unilateral imposition of waivers, indicated an effort to undermine the bargaining power of the newly recognized union.
Duty to Bargain Collectively
The Supreme Court reiterated the principle that the duty to bargain collectively is mutual and requires good fai
...continue readingCase Syllabus (G.R. No. 220383)
Background of the Case
- The case involves a petition for review filed by the SONEDCO Workers Free Labor Union (SWOFLU) members, challenging the decisions made by the Court of Appeals regarding their claims against Universal Robina Corporation, Sugar Division-Southern Negros Development Corporation (URC-SONEDCO).
- The petitioners assert that URC-SONEDCO committed unfair labor practices by failing to negotiate in good faith with SWOFLU, the duly recognized exclusive bargaining representative of the rank-and-file employees.
Events Leading to the Dispute
- On May 6, 2002, URC-SONEDCO entered into a Collective Bargaining Agreement (CBA) with the Philippine Agricultural Commercial and Industrial Workers Union (PACIWU-TUCP) which included wage increases for employees.
- Following a certification election conducted on May 17, 2002, SWOFLU won and replaced PACIWU-TUCP as the exclusive bargaining representative.
- Despite SWOFLU's certification as the sole bargaining agent, URC-SONEDCO refused to negotiate a new CBA, citing the existing 2002 CBA with PACIWU-TUCP.
Key Developments Post-CBA Expiration
- The 2002 CBA expired on December 31, 2006, without a new agreement in place.
- In August 2007, URC-SONEDCO unilaterally offered economic benefits to employees contingent upon their signing of waivers that postponed the effectiveness of any subsequent CBA to