Manila Fashions, Inc. v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Respondent union, Nagkakaisang Manggagawa ng Manila Fashions, Inc., filed a complaint against petitioner Manila Fashions, Inc. on behalf of 150 members. The complaint alleged non-compliance with Wage Order Nos. NCR-02 and 02-A, which mandated a P12.00 wage increase effective January 8, 1991. This non-compliance resulted in underpayments of basic pay, 13th month pay, service incentive leave pay, legal holiday pay, night shift differential, and overtime pay. 2. Procedural History: The Labor Arbiter ruled in favor of the employees, finding the provision in the Collective Bargaining Agreement (CBA) condoning the wage increase void and ordering petitioner to pay P900,012.00. Both parties appealed to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter's decision, dismissing the union's appeal as filed out of time and finding petitioner's arguments unpersuasive. 3. The Petition: Petitioner seeks review of the NLRC's decision, primarily arguing that the condonation of the wage increase implementation, as stipulated in Section 3, Article VIII of the CBA, is valid. Alternatively, petitioner contends that the computation of the award was erroneous and arbitrary. The petition is filed under Rule 65 of the Rules of Court, seeking to annul the NLRC's affirmation of the Labor Arbiter's award.
Issue(s)
Whether the condonation of the implementation of Wage Order No. NCR-02 and 02-A contained in Section 3, Article VIII of the CBA is valid. Whether the computation of the award was erroneous and arbitrary.
Ruling
The petition is DISMISSED. The order of the National Labor Relations Commission affirming the decision of the Labor Arbiter awarding the total amount of P900,012.00 to the complainants is AFFIRMED.
Ratio Decidendi
On the validity of the CBA provision condoning the Wage Order: The Supreme Court sustained the decision of the Labor Arbiter, as affirmed by the NLRC, that the condonation provision in the CBA did not exempt petitioner from complying with Wage Order Nos. NCR-02 and 02-A. A Collective Bargaining Agreement, while allowing parties to stipulate terms convenient to them, cannot include provisions contrary to law, morals, good customs, public order, or public policy. Section 3, Article VIII of the CBA was deemed void because it contravened the mandate of the Wage Order regarding a mandatory wage increase. The Court reiterated the principle that only the Tripartite Wage Productivity Board of the DOLE has the authority to grant exemptions from Wage Orders. If petitioner was experiencing financial distress, it should have applied for a wage exemption through the proper channels, rather than attempting to circumvent the law through a CBA provision. The Court emphasized that parties to a CBA cannot unilaterally set wages lower than the minimum wage prescribed by law, as this would defeat the purpose of wage legislation and potentially lead employees to accept lower wages unwittingly. The cases cited by petitioner were distinguished as they involved compromise settlements recognized by law, not stipulations in a CBA that contravened a statute. On the alleged erroneous and arbitrary computation of the award: The Supreme Court rejected petitioner's alternative argument that the computation of the award was erroneous and arbitrary. This contention was deemed to have been raised for the first time before the Supreme Court, as it was apparently not brought to the attention of the NLRC. Raising such an issue for the first time on appeal is contrary to basic principles of fair play, justice, and due process. Furthermore, the Court's jurisdiction in a petition for certiorari under Rule 65 is generally limited to reviewing issues of jurisdiction or grave abuse of discretion, and does not typically extend to re-examining the correctness of the NLRC's evaluation of evidence.
Main Doctrine
A Collective Bargaining Agreement provision condoning the implementation of a Wage Order is void as it contravenes the law, and only the Tripartite Wage Productivity Board of the Department of Labor and Employment can approve an exemption from a Wage Order. Furthermore, issues not raised before the National Labor Relations Commission cannot be raised for the first time before the Supreme Court.