Sonedco Workers Free Labor Union v. Universal Robina Corporation, Sugar Division-Southern Negros Development Corporation
REVERSALFacts
The Antecedents: In 2007 and 2008, Universal Robina Corporation, Sugar Division-Southern Negros Development Corporation (URC-SONEDCO) offered wage increases (₱16.00/day in 2007 and an additional ₱16.00/day in 2008) to its employees. However, to receive these benefits, employees were required to sign waivers stipulating that any subsequent Collective Bargaining Agreement (CBA) negotiated would only be effective on January 1 of the following year. Several members of the SONEDCO Workers Free Labor Union (SWOFLU) refused to sign these waivers, consequently not receiving the wage increases. Procedural History: SWOFLU and its members who refused to sign the waivers filed a complaint for unfair labor practices against URC-SONEDCO, alleging that the waiver requirement interfered with their right to self-organization, collective bargaining, and concerted action. They sought the 2007 and 2008 wage increases and a continuing wage increase of ₱32.00/day from January 1, 2009 onwards. The National Labor Relations Commission (NLRC) and the Court of Appeals (CA) found URC-SONEDCO not guilty of unfair labor practice but ordered the company to grant the 2007 and 2008 wage increases. The claim for the 2009 wage increase was denied, as a new CBA was in effect by then. The Petition: On October 5, 2016, the Supreme Court found URC-SONEDCO guilty of unfair labor practice for failing to bargain in good faith and ordered the company to grant the 2007 and 2008 wage increases. The claim for the 2009 wage increase was denied, with the Court stating that it should have been included in the 2009 CBA. Subsequently, SWOFLU members filed a Motion for Partial Reconsideration, arguing that the ₱32.00/day wage increase had been integrated into the salaries of those who signed the waivers, creating a disparity. They sought the award of the ₱32.00/day wage increase from January 1, 2009, to the present.
Issue(s)
Whether the petitioners are entitled to the ₱32.00/day wage increase from January 1, 2009, to the present. Whether attorney's fees should be awarded.
Ruling
The Motion for Partial Reconsideration is GRANTED. The dispositive portion of the October 5, 2016 Decision is MODIFIED to include the order for URC-SONEDCO to incorporate the wage increase of ₱32.00/day to the wage of all individual petitioners from January 1, 2009, to present, and to pay attorney's fees.
Ratio Decidendi
On the ₱32.00/day wage increase from January 1, 2009, to present: The Court reiterated the general rule that benefits not included in a Collective Bargaining Agreement (CBA) are not demandable. However, it found that the ₱32.00/day wage increase had been integrated into the salaries of employees who signed the waivers in 2007 and 2008. This integration was a reward for waiving their collective bargaining rights, which the Court had previously declared as an unfair labor practice. To deny petitioners this wage increase would perpetuate the discrimination against them, a direct consequence of the employer's unfair labor practice. Therefore, the Court ordered the incorporation of the ₱32.00/day wage increase to eliminate this discrimination and address all consequences of the unfair labor practice. The grant of this increase was not considered an additional benefit outside the CBA but rather a rectification of an unfair labor practice. On attorney's fees: Considering that exemplary damages were imposed, the Court deemed it proper to grant attorney's fees to the petitioners.
Main Doctrine
A wage increase not included in a Collective Bargaining Agreement is generally not demandable, but if withheld by an employer as part of its unfair labor practice against union members, such benefit should be granted to eliminate discrimination resulting from the unfair labor practice.