Holy Cross of Davao College, Inc. v. Holy Cross of Davao Faculty Union - KAMAPI
REITERATIONFacts
The Antecedents: Jean Legaspi, a permanent English teacher at Holy Cross of Davao College, Inc. (petitioner), applied for the 1999 Monbusho scholarship grant sponsored by the Japanese Government. Petitioner had a Collective Bargaining Agreement (CBA) with respondent Holy Cross of Davao College Faculty Union – KAMAPI, which included a faculty development scholarship provision. Legaspi was selected for the scholarship and requested a study leave with grant-in-aid equivalent to 18 months' salary and allowance, as per the CBA. Petitioner denied the grant-in-aid, citing its "Policy Statement and Guidelines for Trips Abroad for Professional Growth," but granted a 12-month study leave without pay. Procedural History: The respondent union filed a complaint for payment of grant-in aid with the National Conciliation and Mediation Board (NCMB). The parties agreed to submit the case for voluntary arbitration. The Voluntary Arbitrator ruled in favor of Legaspi, ordering petitioner to pay the grant-in aid benefits. Petitioner's motion for reconsideration was denied. Petitioner then filed a petition for review with the Court of Appeals, which affirmed the Voluntary Arbitrator's decision. The Court of Appeals denied petitioner's motion for reconsideration, leading to the present petition for review on certiorari. The Petition: Petitioner contended that the Court of Appeals erred in interpreting the CBA, restricting its academic freedom, and that Legaspi failed to meet the CBA's substantive requirements (course within her area of competence and acquisition of a higher academic degree). Petitioner argued the Monbusho scholarship was a non-degree program outside her area of competence (English).
Issue(s)
Whether Jean Legaspi is entitled to grant-in aid benefits under the CBA. Whether the Monbusho scholarship grant falls within the scope of "higher studies" and "area of competence" as contemplated by the CBA and petitioner's policy. Whether petitioner's "Policy Statement and Guidelines for Trips Abroad for Professional Growth" can qualify or limit the terms of the CBA.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals are AFFIRMED. Petitioner is ordered to pay Miss Jean A. Legaspi her grant-in aid benefit equivalent to her salary, COLA, and other benefits under the law and CBA during the period of her scholarship grant.
Ratio Decidendi
On whether Jean Legaspi is entitled to grant-in aid benefits under the CBA: The Court affirmed the ruling that Jean Legaspi is entitled to the grant-in aid benefits. The Court reiterated the principle that any doubt or ambiguity in a contract between management and union members should be resolved in favor of the latter, citing Article 1702 of the Civil Code. The specific provision of Section 1, Article XIII of the CBA clearly states that the Management shall grant academic personnel a grant-in-aid program when scholarship opportunities arise, affording them a leave of absence to further their studies with a grant-in-aid equivalent to their salary and allowance. The Court found that Legaspi met the conditions for such a grant, as the scholarship was for professional growth and further studies. On whether the Monbusho scholarship grant falls within the scope of "higher studies" and "area of competence" as contemplated by the CBA and petitioner's policy: The Court held that the Monbusho scholarship, despite being a non-degree program and conducted in Japanese, was clearly related to Legaspi's work and constituted "higher studies." The Court noted that the CBA provision on "higher studies" was broad and did not specify that it must lead to a formal degree. The Court emphasized that the training program's content, which included educational management, methods of education, and study of special subjects, was relevant to enhancing Legaspi's effectiveness as a teacher. The fact that the medium of instruction was Japanese did not negate the program's relevance, as the course content was designed to hone her skills. Furthermore, the certificate granted by a premier foreign institute was an added higher qualification. On whether petitioner's "Policy Statement and Guidelines for Trips Abroad for Professional Growth" can qualify or limit the terms of the CBA: The Court ruled that unilaterally imposed rules or policies by management that qualify the terms contained in the CBA are subordinate to the CBA itself. The Court of Appeals correctly held that such rules, formulated by the petitioner a few months before Legaspi's application, were merely suppletory and could neither contradict nor undermine the terms found in the CBA. The CBA is considered the law between the parties, and its terms are binding. The petitioner's policy statement, which provided for regular salary during study tours, was consistent with the CBA's grant-in-aid provision, but it could not be used to deny the grant-in-aid altogether.
Main Doctrine
A Collective Bargaining Agreement (CBA) is considered the law between the parties, and its provisions, particularly those concerning faculty development and grant-in-aid for studies, must be interpreted literally and in favor of the employee in case of doubt or ambiguity. Unilaterally imposed rules by management that qualify the terms of the CBA are subordinate to the CBA itself.