General Rubber and Footwear Corporation v. Drilon
REITERATIONFacts
The Antecedents: On December 26, 1984, Wage Order No. 6 was issued, increasing statutory minimum wage and cost of living allowance. Petitioner General Rubber and Footwear Corporation applied for exemption, which was denied by the National Wages Council (NWC) on March 4, 1985, ordering full compliance. Petitioner filed a Motion for Reconsideration. On May 25, 1985, some union members declared a strike. Three days later, petitioner and Leopoldo Sto. Domingo, representing the striking workers, entered into a Return-to-Work Agreement. Article 4 of this Agreement stipulated that petitioner would implement Wage Order No. 6 effective May 30, 1985, and withdraw its Motion for Reconsideration, in consideration of the union and its members not demanding differential pay from November 1, 1984, to May 29, 1985. This Agreement was ratified on July 30, 1985, by 268 union members. Petitioner withdrew its Motion for Reconsideration with the NWC on June 5, 1985, which was allowed by the NWC on June 13, 1985, noting petitioner's compliance effective May 30, 1985. Approximately 100 union members did not ratify the Agreement, believing the NWC's March 4, 1985 Order had become final. On July 10, 1985, these minority members, through the respondent union, applied for a writ of execution of the NWC Order. Procedural History: Petitioner opposed the writ of execution, arguing the Agreement superseded the NWC Order and that majority ratification bound all members. The respondent union countered that the Agreement, involving money claims, was not binding on non-consenting members, citing the doctrine in Kaisahan ng Manggagawa sa La Campana v. Sarmiento. The National Capital Region Director initially ordered the issuance of a writ of execution on September 20, 1985, for P90,090.00. Petitioner moved to quash this writ. In an Order dated January 15, 1986, the Director reversed his earlier ruling, sustaining petitioner's contention that minority members were bound by the majority ratification. The respondent union's motion for reconsideration, treated as an appeal to the Minister of Labor, resulted in a decision dated December 19, 1986, setting aside the Director's January 15, 1986 Order. The Minister held that the 100 members who did not sign the Agreement could not be bound by its waiver of benefits and that the NWC Order of March 4, 1985, remained enforceable for them. The case was remanded for issuance of a writ of execution. The Petition: Petitioner filed the instant Petition for Certiorari seeking to annul the Minister of Labor's decision.
Issue(s)
Whether the Return-to-Work Agreement, specifically Article 4 thereof, is binding upon union members who did not individually ratify it. Whether the National Wages Council's Order dated March 4, 1985, became final and executory with respect to the non-ratifying union members.
Ruling
The petition is DISMISSED for lack of merit. The decision of the Minister of Labor dated December 19, 1986, is affirmed.
Ratio Decidendi
On the binding effect of the Return-to-Work Agreement on non-ratifying members: The Court held that Article 4 of the Return-to-Work Agreement was not enforceable against the union members who did not individually ratify it. The Court reiterated the doctrine established in Kaisahan ng Manggagawa sa La Campana v. Sarmiento, which states that money claims due to laborers cannot be the object of settlement or compromise effected by a union or counsel without the specific individual consent of each laborer concerned. The beneficiaries of such claims are the individual complainants themselves, and the union can only assist them, not decide for them. Therefore, the waiver of accrued money claims, such as wage differentials, is a personal right that must be personally exercised by the worker. The officers or the majority of the union lacked the authority to waive the accrued rights of dissenting minority members, even under a union shop provision. The Court emphasized that the protective shield of this doctrine is necessary not only against employers but also against union management and even against the workers' own imprudence or impecuniousness. The Court clarified that it was not stating that accrued money claims can never be waived, but that in this specific case, the private respondents never purported to waive their claims, and even if they had, the validity of such a waiver would raise a separate public policy question not necessary to address here. On the finality and executory nature of the NWC Order: Since Article 4 of the Return-to-Work Agreement was not enforceable against the non-consenting union members, the Order of the National Wages Council dated March 4, 1985, requiring petitioner to comply with Wage Order No. 6 from November 1, 1984, onward, must be regarded as having become final and executory insofar as the non-consenting union members were concerned. Consequently, enforcement of that Order by a writ of execution was proper. The decision of the Minister of Labor, which upheld the right of these 100 workers to claim their differential pay, was therefore in accordance with law and did not constitute a grave abuse of discretion.
Main Doctrine
A waiver of accrued money claims by union members, including wage differentials, is a personal right that requires the individual consent or ratification of each affected member to be legally effective. A union, its officers, or a majority of its members cannot validly waive the accrued rights of dissenting minority members.