Faculty Association of Mapua Institute of Technology v. Court of Appeals
REITERATIONFacts
The Antecedents: The Faculty Association of Mapua Institute of Technology (FAMIT) and Mapua Institute of Technology (MIT) entered into a Collective Bargaining Agreement (CBA) effective June 1, 2001. The CBA incorporated a new faculty ranking instrument and established specific pay rates for faculty members. MIT later proposed amendments to certain annexes of the CBA, specifically concerning the faculty ranking and pay rates, citing perceived flaws and omissions. FAMIT rejected the proposal, asserting that the changes would violate the ratified CBA and result in a diminution of rank and benefits. Separately, MIT adopted a new formula for determining the pay rates of high school faculty based on hours of service instead of the agreed rate per load, which FAMIT also opposed. Procedural History: FAMIT brought the issues to the National Conciliation and Mediation Board. The case was submitted to a Panel of Voluntary Arbitrators, which ruled in favor of FAMIT, ordering MIT to implement the agreed point range system and comply with the provisions on high school faculty pay. On appeal, the Court of Appeals reversed the Voluntary Arbitrators' decision, granting MIT's proposal to amend the annexes and implement its proposed faculty ranking instrument and pay data. The Petition: FAMIT filed a petition for review with the Supreme Court, seeking to reverse the Court of Appeals' decision and reinstate the ruling of the Voluntary Arbitrators.
Issue(s)
Whether MIT may unilaterally alter, change, and/or modify provisions of the Collective Bargaining Agreement (CBA) it negotiated, entered into, and signed with FAMIT, specifically regarding faculty ranking. Whether MIT may unilaterally change, alter, and/or replace a provision or formula embodied in a perfected, existing, and enforced CBA to the prejudice, specifically to the diminution of salary/benefits, for its high school faculty.
Ruling
The Supreme Court granted the petition, reversed the decision of the Court of Appeals, and reinstated the decision of the Office of the Voluntary Arbitrators. MIT's unilateral changes in the ranking of college faculty and the computation of high school faculty salary were declared null and void for being violative of the parties' CBA and applicable law.
Ratio Decidendi
On the issue of unilateral modification of the CBA regarding faculty ranking: The Supreme Court held that MIT's proposed new point range system for faculty ranking was an unauthorized modification of Annex "C" of the 2001 CBA. The proposed system introduced a substantially different faculty classification and could lead to a demotion in rank and a consequent reduction in salary increases, directly violating Section 8, Article V of the CBA. The Court emphasized that Article 253 of the Labor Code mandates that neither party shall terminate nor modify a CBA during its lifetime, requiring the parties to keep the status quo and maintain the terms and conditions of the existing agreement until a new one is reached. The CBA, once ratified, constitutes the law between the parties, and its provisions must be respected. On the issue of unilateral change in the pay formula for high school faculty: The Supreme Court agreed with FAMIT that MIT could not unilaterally change the CBA formula for determining the salary of high school faculty. The 2001 CBA, specifically Section 2 of Article VI, clearly provided for a rate per load basis for calculating high school faculty salaries, not a rate per hour basis as MIT unilaterally adopted. The Court reiterated the principle that in case of doubt in the interpretation of any law or provision affecting labor, such should be interpreted in favor of labor. MIT's adoption of a new pay formula without FAMIT's knowledge and consent was deemed a violation of the CBA and the governing law.
Main Doctrine
A Collective Bargaining Agreement (CBA) constitutes the law between the parties and neither party may unilaterally terminate or modify its terms during its lifetime without adhering to the notice and negotiation requirements stipulated in Article 253 of the Labor Code. Any unilateral change that results in the diminution of rank or pay is violative of the CBA and applicable law.