Philippine Geothermal, Inc. v. Undersecretary of Labor Carmelo Noriel
REITERATIONFacts
The Antecedents: The Federation of Free Workers-PGI Chapter (Union) submitted proposals for CBA renegotiation with Philippine Geothermal, Inc. (Company). Pending a new CBA, the Company granted a P200.00 monthly salary increase effective November 1, 1986. The Union declared a deadlock and filed a notice of strike. Labor Secretary Drilon assumed jurisdiction, ordered a return to work, and awarded an P800.00 monthly wage increase for the first year, among other benefits, directing parties to incorporate awards and agreed items into the new CBA. A new CBA was signed, effective retroactively to November 1, 1986, incorporating the P800.00 increase. Procedural History: The Company implemented the P800.00 increase by deducting the P200.00 previously granted, resulting in a net increase of P600.00. The Union filed a notice of strike, alleging CBA violation. The dispute was submitted to Labor Undersecretary Carmelo C. Noriel for arbitration. Noriel ruled that the Company must pay the P200.00 monthly salary differential, representing the first-year increase effective November 1, 1986, and comply with the P800.00 anniversary increase. The Company's motion for reconsideration was denied. The Petition: The Company filed a petition assailing Noriel's decision and order for allegedly being rendered with grave abuse of discretion, arguing that a prior agreement stipulated the P200.00 increase was creditable to the P800.00 award. The National Power Corporation (NPC) sought to intervene, claiming an indirect interest as the Company's reimbursement party.
Issue(s)
Whether the P200.00 salary increase granted during CBA negotiations is creditable to the P800.00 wage increase mandated by the new CBA. Whether the Labor Undersecretary committed grave abuse of discretion in rendering his decision and order.
Ruling
The petition is dismissed. The National Power Corporation's petition for leave to file intervention and motion to adopt petition is denied. The temporary restraining order issued on June 1, 1988, is lifted.
Ratio Decidendi
On the issue of whether the P200.00 salary increase is creditable to the P800.00 wage increase: The Court held that the P200.00 monthly salary increase granted by the Company during the pendency of CBA negotiations was an act of grace unilaterally extended to the Union members and was not creditable to the P800.00 monthly wage increase mandated by the new CBA. The Court found the Company's assertion of a clear agreement to credit the P200.00 increase to be doubtful, as the Union pointed to minutes of a meeting indicating the agreement was precisely to exclude the P200.00 from future negotiated increases. Furthermore, the Company itself declared the P200.00 increase was granted pursuant to the last CBA and Article 254 of the Labor Code, despite having no obligation to do so. The March 1987 Order of Secretary Drilon and the new CBA were clear and unequivocal, mandating the P800.00 increase without qualification or deduction. Therefore, the P200.00 increase was a separate and distinct grant that must be given in addition to the P800.00 increase. On the issue of grave abuse of discretion: The Court found no evidence that the respondent public official exercised his power in an arbitrary and despotic manner, amounting to a lack or excess of jurisdiction. The Court reiterated the settled rule that decisions of voluntary arbitrators, based on their findings of fact and application of law, are entitled to the highest respect. Since the issue primarily involved a review of facts, particularly the existence and relevance of a purported agreement, and the petitioner failed to substantiate its claim with sufficient proof from the meeting minutes, the petition assailing the decision on factual grounds was dismissed. The Court emphasized that it was incumbent upon the petitioner to prove its alleged agreement, which it failed to do, while the Union successfully presented evidence from the same minutes to the contrary.
Main Doctrine
A unilaterally granted salary increase during CBA negotiations, considered an act of grace, cannot be withdrawn or credited against a subsequent CBA award unless explicitly agreed upon by the parties. Decisions of voluntary arbitrators are entitled to the highest respect, and petitions assailing them solely on questions of fact must be dismissed.