Free Telephone Workers Union v. Philippine Long Distance Telephone Company
REITERATIONFacts
The Antecedents: The Free Telephone Workers Union, representing 1,345 rank and file employees of Philippine Long Distance Telephone Company (PLDT), demanded a new collective bargaining agreement, initially seeking a P1.00 per hour salary increase, later reduced to P0.90 per hour over two years, while PLDT counter-offered P0.10 per hour over three years. Negotiations reached an impasse, leading the union to file a strike notice. PLDT proposed an interim increase of P0.15 per hour from November 1 to December 31, 1964, conditional on withdrawing the strike notice and reverting wages if no agreement was reached by December 31, 1964, but the union rejected this and declared a strike on November 1, 1964. Procedural History: The dispute was certified by the President to the Court of Industrial Relations (CIR) on November 3, 1964. On November 9, 1964, the CIR rendered a partial decision ordering PLDT to pay a P0.16 per hour wage increase to its rank and file employees for one year from November 9, 1964, leaving the wage increase for the second and third years pending. The union moved for reconsideration, and on November 17, 1964, the CIR en banc affirmed the partial decision, with one judge dissenting on the issue of minimum salaries for certain employees. On November 26, 1965, while the appeal was pending, the CIR rendered a 'Third Partial Decision' granting P0.16 per hour for the second year and P0.18 per hour for the third year. The Petition: The union appealed the CIR's partial decision and en banc resolution, raising issues regarding minimum wages for certain employees, conversion of hourly to monthly salaries, and the sufficiency of the P0.16 per hour wage increase award.
Issue(s)
Whether the CIR erred in failing to consider the evidence and law regarding minimum wages for certain employees. Whether the CIR erred in not ruling on the conversion of hourly to monthly salaries. Whether the CIR's award of a P0.16 per hour wage increase is supported by substantial evidence.
Ruling
The Supreme Court affirmed the resolution of the Court of Industrial Relations. The Court held that issues not raised before the lower court are not proper subjects for review. The Court also found that the P0.16 per hour wage increase award was supported by substantial evidence.
Ratio Decidendi
On the issue of minimum wages for certain employees: The Court ruled that this issue was raised for the first time on appeal and was not a subject of the CIR's decision. Therefore, it was not a proper subject for review by the Supreme Court and should be taken up in a separate proceeding below. The Court emphasized that no findings of fact were made by the respondent court on this matter, as there was no reason to do so at that stage. On the issue of conversion of salaries to a monthly basis: The Court noted that the CIR en banc did not rule on this question, and the union did not raise it in its motion for reconsideration or memorandum. Consequently, the Supreme Court was not in a position to resolve the issue intelligently. The Court found the union's reliance on supervisors being paid monthly as insufficient grounds, as supervisors belong to a different bargaining unit with potentially different employment conditions. The matter was left to be ventilated and decided by the trial court. On the issue of substantial evidence supporting the P0.16 per hour wage increase: The Court reiterated the definition of substantial evidence as "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." The Court found that the CIR's resolution met this test. The CIR considered pertinent factors, including the increase in the cost of living in the Manila Area, as evidenced by consumer price index data. It also compared the wage increase awarded to the rank and file employees with the increases given to supervisors and the rates of skilled laborers in the Manila Area. The Court noted that the P0.16 per hour increase was substantial, representing a significant percentage increase over existing rates and outpacing the rise in the cost of living and skilled labor rates. Furthermore, the CIR considered the prevailing rates for similar work in the Manila Area, finding PLDT's rates to be among the highest. The company's financial situation, including its expansion and reinvestment of surplus earnings, was also taken into account to ensure a just and reasonable profit for the investor while meeting service exigencies. The Court highlighted that the CIR endeavored to conciliate the parties' differences and, after weighing the evidence, arrived at the award. The Court concluded that the award was supported by the evidence on record and found no sufficient justification to alter or modify it.
Main Doctrine
The Court of Industrial Relations' award of a wage increase is affirmed if supported by substantial evidence, considering factors such as cost of living, prevailing rates, and the company's financial situation. Issues not raised before the lower court are not proper subjects for review.