Case Summary (G.R. No. 237063)
Factual Background
In 2007 URC-SONEDCO offered a P16.00 per day wage increase to employees who signed a waiver providing that any subsequent Collective Bargaining Agreement would be effective only on January 1, 2008. No CBA was in effect at the time of the 2007 offer. Some members of SONEDCO Workers Free Labor Union refused to sign the waiver. In 2008 URC-SONEDCO again offered a similar P16.00 per day increase conditioned on a waiver rendering any 2008 CBA effective only on January 1, 2009; several union members again refused to sign and therefore did not receive the additional P16.00 for 2008.
Filing of the Unfair Labor Practice Complaint
On July 2, 2009 the union and its members who had refused to sign the 2007 and 2008 waivers filed a complaint for unfair labor practices against URC-SONEDCO. They alleged that conditioning release of wage increases upon waivers constituted unlawful interference with the employees’ rights to self-organization, collective bargaining, and concerted action. The petitioners sought a P16.00 per day wage increase for 2007, an additional P16.00 per day for 2008, and a continuing wage increase of P32.00 per day from January 1, 2009 onwards.
Proceedings Before the NLRC and Court of Appeals
Both the National Labor Relations Commission and the Court of Appeals found URC-SONEDCO not guilty of unfair labor practice on the merits. Those tribunals nevertheless ordered URC-SONEDCO to give the petitioners the same benefits their co-workers received for 2007 and 2008. The Court of Appeals denied the claim for the 2009 wage increase, explaining that a new Collective Bargaining Agreement was already in effect by 2009 and that, as there was no provision in the existing CBA regarding a P16.00 per day wage increase for 2009, the NLRC could not impose such payment.
Supreme Court Decision of October 5, 2016
In SONEDCO Workers Free Labor Union v. Universal Robina Corporation, Sugar Division Southern Negros Development Corporation, G..R No. 220383, October 5, 2016, the Supreme Court reversed the NLRC and Court of Appeals on liability and found URC-SONEDCO guilty of unfair labor practice for failing to bargain in good faith. The Court held that URC-SONEDCO had restricted the union’s bargaining power by requiring rank-and-file employees to waive their collective bargaining rights in exchange for wage increases. The Court ordered payment of the P16.00 per day increases for 2007 and 2008 to the petitioners and awarded moral damages of P100,000.00 and exemplary damages of P200,000.00 to the union, but it denied the petitioners’ claim for the 2009 continuing wage increase, noting that continuation of such a benefit required inclusion in the 2009 CBA.
Post-Decision Motions
Respondent URC-SONEDCO filed a Motion for Reconsideration on December 27, 2016, reiterating prior arguments; the motion was denied. On February 20, 2017 the petitioners filed a Motion for Partial Reconsideration seeking relief in four respects: payment of P16.00 per day for 2007; payment of P16.00 per day for 2008; incorporation of the P32.00 per day continuing wage increase from January 1, 2009 to present; and an award of attorney’s fees. URC-SONEDCO filed a Comment/Opposition arguing that the 2009 wage increase had already been ruled upon and that, because it was not included in the 2009 CBA, it could not be demanded.
Evidence of Wage Integration
To support the contention that the P32.00 per day increase had been integrated into the salaries of employees who signed the waivers, petitioners attached a joint affidavit dated January 18, 2017 signed by twenty-six URC-SONEDCO employees. The affiants averred that they had signed the 2007 and 2008 waivers and that they continued to receive a P32.00 per day higher wage than petitioners as a result.
Legal Principle on Collective Bargaining Agreements and Exception
The Court reiterated the general rule that an existing Collective Bargaining Agreement governs the parties’ relationship and that benefits not included in the CBA are generally not demandable. The Court nevertheless recognized an exception under the peculiar facts of this case. Because respondent had committed an unfair labor practice by inducing waivers and had integrated the wage increase into the salaries of those who signed, continuing to deny the identical benefit to petitioners would perpetuate discriminatory consequences of the unlawful act.
Court’s Reasoning and Relief on the Continuing Wage Increase
The Court concluded that all the consequences of the proven unfair labor practice must be addressed and that affording the P32.00 per day continuing increase to petitioners would eliminate the discrimination arising from respondent’s conduct. The Court therefore found it proper to modify its October 5, 2016 dispositive order to require URC-SONEDCO to incorporate the P32.00 per day increase into the wages of the individual petitioners from January 1, 2009 to present.
Modified Disposition and Awards
The
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Case Syllabus (G.R. No. 237063)
Parties and Procedural Posture
- SONEDCO Workers Free Labor Union and numerous rank-and-file employees filed an unfair labor practice complaint against Universal Robina Corporation, Sugar Division-Southern Negros Development Corporation (URC-SONEDCO).
- The complaint challenged URC-SONEDCO's conditioning of wage increases on employees signing waivers that deferred the effectivity of any subsequent Collective Bargaining Agreement.
- The National Labor Relations Commission and the Court of Appeals initially found URC-SONEDCO not guilty of unfair labor practice while nonetheless ordering the employer to give the petitioners the 2007 and 2008 benefits.
- This Court, in SONEDCO Workers Free Labor Union v. Universal Robina Corporation, Sugar Division Southern Negros Development Corporation, G.R. No. 220383, October 5, 2016, reversed and found URC-SONEDCO guilty of unfair labor practice for failing to bargain in good faith.
- URC-SONEDCO filed a Motion for Reconsideration of this Court's October 5, 2016 Decision which was denied, and petitioners subsequently filed a Motion for Partial Reconsideration focusing on the 2009 continuing wage claim.
Key Factual Allegations
- URC-SONEDCO offered a P16.00/day wage increase in 2007 on condition that employees sign a waiver making any future Collective Bargaining Agreement effective only from January 1, 2008.
- URC-SONEDCO offered a further P16.00/day increase in 2008 on a similar waiver making any future Collective Bargaining Agreement effective only from January 1, 2009.
- Several union members refused to sign the waivers and consequently did not receive the combined P32.00/day increase beginning 2009.
- Petitioners alleged that the waivers constituted inducement to forgo collective bargaining rights and therefore amounted to unfair labor practice.
Procedural History
- Petitioners filed their unfair labor practice complaint on July 2, 2009.
- The NLRC and the Court of Appeals found URC-SONEDCO not guilty of unfair labor practice, but they ordered the employer to grant the 2007 and 2008 increases to petitioners.
- This Court reversed on October 5, 2016, finding URC-SONEDCO guilty of unfair labor practice and ordering payment of the 2007 and 2008 wage increases plus moral and exemplary damages.
- Petitioners later moved for partial reconsideration to secure the continuing P32.00/day increase from January 1, 2009 to present, and URC-SONEDCO opposed that motion.
Issues Presented
- Whether petitioners who refused to sign the 2007 and 2008 waivers were entitled to the P16.00/day wage increase for 2007 and the additiona