Supreme Court affirms NLRC’s authority on collective bargaining agreement
The Supreme Court recently confirmed that the National Labor Relations Commission (NLRC) holds the power to enforce the terms of a collective bargaining agreement (CBA) in cases involving unfair labor practices. This ruling clarifies the NLRC’s role amid disputes between employers and employees over labor agreements.
The high court’s Third Division upheld the NLRC’s directive for Guagua National Colleges (GNC) to pay its workers agreed economic benefits, including rice subsidy, longevity pay, and emergency relief allowance. However, the Supreme Court modified how these benefits were computed.
Background of the Guagua National Colleges labor dispute
The case began when GNC questioned the NLRC’s order requiring the school to grant these benefits. The Pampanga-based school argued that only voluntary arbitrators had the authority to implement the CBA, not the NLRC. However, the Supreme Court clarified that while voluntary arbitrators typically handle CBA implementation, the Labor Code allows the NLRC to intervene in cases involving gross violations amounting to unfair labor practices.
In April 2009, GNC’s faculty, non-teaching staff, and maintenance unions expressed their intent to renew the CBA expiring on May 31 that year. Instead of replying or offering counter proposals, GNC called for a meeting on May 15, but no agreement was reached. Subsequent meetings failed to settle the negotiations as management later stated it had no plans to grant the monetary proposals.
Negotiations break down and strike threat looms
By August 24, 2009, GNC confirmed certain benefits to be included in the new CBA, such as loyalty pay, cash gift, rice subsidy, birthday gift, and clothing allowance. However, it rejected the unions’ demand for a higher signing bonus. Since no agreement was signed, the unions filed a preventive mediation case, eventually leading to a strike notice.
The unions accused GNC of bad faith bargaining, gross violation of the CBA, and reducing benefits by stopping some payments. The strike was averted when the labor secretary took jurisdiction over the dispute.
NLRC finds GNC guilty of unfair labor practice
On March 31, 2011, the NLRC ruled that GNC committed unfair labor practice by failing to bargain in good faith. It declared the final draft of the CBA as the binding agreement from June 1, 2009, to May 31, 2014, with benefits effective retroactively from June 1, 2009.
After the decision became final, the NLRC ordered GNC to pay the agreed benefits from 2009 up to 2017. GNC challenged this, insisting only voluntary arbitrators could enforce CBA terms. The Court of Appeals, however, upheld the NLRC’s ruling.
Supreme Court’s final ruling on collective bargaining agreement enforcement
The Supreme Court partially granted GNC’s petition but reaffirmed Article 274 of the Labor Code, which empowers the NLRC to exercise jurisdiction over gross CBA violations that amount to unfair labor practices. The court recognized that the dispute was a compulsory arbitration case since it nearly led to a strike before the labor secretary intervened.
The court noted that after the NLRC found GNC guilty of unfair labor practice, it was best positioned to enforce the CBA. The relationship between the parties had deteriorated due to prolonged legal battles over economic benefits.
The court warned that requiring the parties to submit the case to voluntary arbitrators would only cause multiple lawsuits and delay resolving their rights and obligations.
Limitations on NLRC enforcement and benefit computations
However, the Supreme Court ruled the NLRC exceeded its authority in two areas: enforcing the signing bonus and awarding benefits beyond the five-year CBA term. The court clarified that the NLRC cannot impose the signing bonus and must limit benefit computations to the 2009-2014 period.
This decision underscores the NLRC’s vital role in protecting workers’ rights amid unfair labor practices while setting clear boundaries for its enforcement powers.
For more news and updates on collective bargaining agreement enforcement, visit Filipinokami.com.
