Case Summary (G.R. No. 224558)
Factual Background
URSUMCO and NAMA-URSUMCO-NFL had previously negotiated a Collective Bargaining Agreement (CBA) valid from January 1, 2010, to December 31, 2014. The CBA specified employment classifications, including Permanent or Regular Employees and Regular Seasonal Employees. In 2011, NAMA-URSUMCO-NFL filed grievances on behalf of 78 regular seasonal employees, seeking their reclassification from seasonal to permanent regular status and their salary standardization. Following unsuccessful attempts to resolve these grievances through the grievance machinery, the matter was submitted to voluntary arbitration.
Parties' Positions During Arbitration
In its Position Paper, NAMA-URSUMCO-NFL argued that the regular seasonal employees performed work similar to that of permanent employees during the milling season and also engaged in skilled jobs while performing substantially similar tasks, yet they remained underpaid. URSUMCO countered that NAMA-URSUMCO-NFL was estopped from challenging the employee classification established in the CBA and that the nature of the work during non-milling seasons was not comparable to that of permanent employees, thereby upholding its management prerogative.
Voluntary Arbitrator's Ruling
The Voluntary Arbitrator (VA) sided with NAMA-URSUMCO-NFL, ruling that URSUMCO's long-standing practice of continuously providing work to regular seasonal employees constituted a waiver of the classification as per the CBA. The VA declared that the concerned employees should be considered permanent employees if they had accumulated at least 300 days of service during the off-season. However, it denied the Union's request to standardize salaries amongst employees in similar positions.
Court of Appeals Decision
URSUMCO appealed the VA's decision to the Court of Appeals (CA), which affirmed the VA's ruling. The CA concluded that the employees were not temporarily laid off during the off-season, as they performed necessary repair and maintenance tasks, thus solidifying their employment status. Moreover, the CA ruled that the nature of employment is determined by law rather than the terms of the CBA, allowing NAMA-URSUMCO-NFL to challenge the employee classification.
Issues Raised in the Petition
URSUMCO filed a petition questioning whether the CA ruled contrary to law and jurisprudence by affirming the VA's decision that URSUMCO's seasonal employees should be classified as permanent employees. URSUMCO argued that the CBA served as the governing law and that NAMA-URSUMCO-NFL's request for regularization disregarded the CBA's provisions. They maintained that their actions during the off-milling season did not alter the employees' seasonal status.
Court's Ruling
The Supreme Court ruled that URSUMCO’s petition was without merit. The Court affirmed that while the CBA is binding, the employment status is determined by law and cannot be altered by contract stipulations. According to Article 295 of the Labor Code, different employment statuses are legally defined, including regular and seasonal categories. The Court noted that the employees had not been laid off during the off-milling season but had been assigned necessary repairs, indicating that they should not be solel
...continue readingCase Syllabus (G.R. No. 224558)
Case Background
- The case involves a petition for review on certiorari filed by Universal Robina Sugar Milling Corporation (URSUMCO) under Rule 45 of the Rules of Court.
- The petition seeks to nullify the April 15, 2015 Decision and the April 21, 2016 Resolution of the Court of Appeals (CA), which upheld the May 30, 2012 Decision of the Voluntary Arbitrator (VA) from the National Conciliation and Mediation Board, Region VII, Cebu City.
- URSUMCO is a domestic corporation engaged in sugar milling, while NAMA-URSUMCO-NFL is a labor organization representing the regular employees of URSUMCO.
Collective Bargaining Agreement (CBA)
- URSUMCO and NAMA-URSUMCO-NFL entered into a CBA that was effective from January 1, 2010, to December 31, 2014.
- Article VI, Section 2 of the CBA classified employment into categories: Permanent or Regular Employees and Regular Seasonal Employees.
Grievance and Arbitration Process
- From August to September 2011, NAMA-URSUMCO-NFL filed grievances on behalf of 78 regular seasonal employees, seeking their reclassification from regular seasonal to permanent regular status and salary leveling.
- After the grievance machinery was ineffective, the matter was submitted to voluntary arbitration, where both parties submitted position papers outlining their arguments.
Positions of the Parties
NAMA-URSUMCO-NFL's Position:
- Claimed that regular seasonal employees performed the same work as permanent employees during the milling season.
- Argued that some regular seasonal employees undertook skilled jobs during the off-milling season while others did utility jobs.
- Highlighted discrepancies in salary and employment status among employees performing similar functions.
URSUMCO's Counterarguments:
- Asserted that NAMA-URSUMCO-NFL was estopped from challenging the CBA's employee classification.
- Contended that regular seasonal employees only worked during the milling season and were not