Associated Labor Unions-Trade Union Congress of the Philippines v. Letrondo-Montejo
REITERATIONFacts
The Antecedents: Petitioner Associated Labor Unions (ALU-TUCP), representing members at AMS Farming Corporation, and AMS Farming Corporation entered into a five-year Collective Bargaining Agreement (CBA) effective November 1, 1990. Article VII, Section 3 of the CBA listed specific holidays, including "days designated by law for holding referendum and local/national election," as paid regular holidays. The President of the Philippines declared December 4, 1992, a "special day" for the holding of Sangguniang Kabataan (SK) elections nationwide. Employees covered by the CBA claimed holiday pay for this day. Procedural History: AMS Farming Corporation refused the holiday pay claims, asserting that the SK election day was not a regular holiday under the CBA. The dispute was submitted to voluntary arbitration. The parties agreed that the issue was whether the SK Election Day was a regular holiday for purposes of the CBA and that the SK Election Day was a holiday as decreed by the President. On July 19, 1993, the Voluntary Arbitrator dismissed the claim for holiday pay, reasoning that the SK election could not be considered a "local election" because only qualified youth could vote, making it a "working holiday" for most. The Petition: Petitioner sought certiorari to set aside the Voluntary Arbitrator's decision, arguing that the SK election day was a "local/national election" under the CBA, entitling their members to holiday pay.
Issue(s)
Whether the Sangguniang Kabataan (SK) Election Day on December 4, 1992, constitutes a "local/national election" within the meaning of Article VII, Section 3 of the Collective Bargaining Agreement (CBA). Whether the employees of AMS Farming Corporation are entitled to holiday pay for December 4, 1992.
Ruling
The decision of the Voluntary Arbitrator dated July 19, 1993, insofar as it dismissed petitioner's claim for holiday pay, is SET ASIDE. Private respondent AMS Farming Corporation is ORDERED to pay petitioner's members their regular holiday pay for December 4, 1992, in accordance with Article VII, Section 3 of the Collective Bargaining Agreement.
Ratio Decidendi
On the issue of whether the SK Election Day is a "local/national election" under the CBA: The Supreme Court held that the SK election is indeed a "local election" within the meaning of the CBA. The Court explained that the Sangguniang Kabataan is an integral part of the local government structure, as established by the Local Government Code (Republic Act No. 7160). The SK chairman is an ex officio member of the Sangguniang Baranggay, and the Pederasyon ng mga Sangguniang Kabataan chairman is an ex officio member of higher local legislative bodies. Therefore, the election for SK members directly pertains to the local governance system. The Court further clarified that the Voluntary Arbitrator's reasoning that it was not a local election because only a specific age group could vote was flawed. The Court pointed out that the President had declared December 4, 1992, a "special day" for the SK elections, and a "special day" is recognized under the Administrative Code. Moreover, the fact that only a specific sector votes does not diminish its character as a regular local election, analogous to sectoral elections for national representatives where only members of specific sectors can vote. The Court emphasized that the CBA provision merely reiterated the concept of paid holidays, which includes days designated by law for general elections. On the entitlement to holiday pay: Consequently, because the SK election day was deemed a "local election" under the CBA and was declared a "special day" by presidential proclamation, it qualified as a paid regular holiday. The Court found that the Voluntary Arbitrator erred in her interpretation of the CBA, leading to the denial of substantial justice to the union members. The Court reiterated that under Article 94 of the Labor Code, "holiday" includes the day designated by law for holding a general election, which encompasses both local and national elections. Therefore, the employer was obligated to pay holiday pay to the employees for December 4, 1992, as stipulated in the CBA.
Main Doctrine
An election for the Sangguniang Kabataan (SK) is considered a "local election" within the contemplation of a Collective Bargaining Agreement (CBA) provision that designates "days designated by law for holding referendum and local/national election" as paid regular holidays, entitling employees to holiday pay.