G.R. No. 90739 October 3, 1991
NATIONAL FEDERATION OF LABOR UNIONS (NAFLU) and FLORANTE ONGBUECO, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and UNION AJINOMOTO, INC., respondents.

FACTS

Florante Ongbueco was a Production Staff Engineer at Union Ajinomoto, Inc. In 1983, pursuant to Batas Pambansa Blg. 73 (the Omnibus Energy Conservation Law), the company designated Ongbueco as its Energy Manager. This appointment required him to submit energy consumption reports and implement conservation programs as mandated by the Bureau of Energy Utilization. Ajinomoto did not grant any salary increase for this designation, contending it did not entail responsibilities beyond the report preparation duties Ongbueco was already performing.
After nearly three years, Ongbueco filed a complaint for underpayment of salary, claiming his designation as Energy Manager constituted a promotion entitling him to a corresponding salary adjustment. The Labor Arbiter ruled in his favor, ordering a salary commensurate with the position. The NLRC Fourth Division affirmed this decision. However, upon a second motion for reconsideration, the NLRC Second Division reversed, dismissing the complaint. Ongbueco and NAFLU elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the designation of an employee as Energy Manager under B.P. Blg. 73, without a statutory provision for a salary increase, automatically entitles the employee to a higher salary as a matter of right.

RULING

The Supreme Court dismissed the petition, upholding the NLRC Second Division’s decision. The Court clarified that B.P. Blg. 73 is an energy conservation law, not a labor law. Its requirement for companies to appoint an Energy Manager is incidental to its primary objective and does not, by itself, create an obligation for the employer to grant a salary increase. The law’s silence on compensation means the matter is left to the discretion of the employer as a management prerogative.
The Court rejected the petitioner’s argument that ambiguities should be resolved in favor of labor, stating that no ambiguity exists where the law is clear. The designation did not alter Ongbueco’s rank or substantially change his duties, as the reporting functions were already part of his assignment prior to the formal appointment. Therefore, the claim for a salary increase lacked legal or contractual basis. The employer’s right to manage its affairs includes determining compensation for additional designations, absent a law or agreement stipulating otherwise.