G.R. No. 218010 , February 6, 2023
FERNAND O. MATERNAL, ET AL., PETITIONERS, VS. COCA-COLA BOTTLERS PHILS., INC. (NOW KNOWN AS COCA-COLA FEMSA PHILS., INC.), RESPONDENT. (Consolidated with G.R. No. 248662)

FACTS

Coca-Cola Bottlers Phils., Inc. (CCBPI) granted its regular rank-and-file employees various one-time bonuses from 1997 to 2007, including One-time Grant, One-time Economic Assistance, One-time Gift, and One-time Transition Bonuses, under different managing companies (Coca-Cola Amatil Ltd., San Miguel Corporation, and later The Coca-Cola Company). These bonuses were given in varying amounts, often based on a percentage of basic salary or a fixed sum. In 2008, the new management stopped granting these bonuses, prompting employees to file complaints for nonpayment. The Labor Arbiter ruled in favor of the employees, declaring the grant of yearly bonuses had become a company practice and ordering CCBPI to pay bonuses for 2008-2010. The National Labor Relations Commission (NLRC) affirmed but modified the award to 2/3 of basic monthly pay based on the average of bonuses from 2001-2007. The Court of Appeals reversed, declaring the employees not entitled to the claimed benefits. The employees elevated the case to the Supreme Court via petitions for review on certiorari.

ISSUE

Whether the one-time bonuses granted by CCBPI from 1997 to 2007 have ripened into a company practice that forms part of the employees’ wages, making them demandable as a matter of right.

RULING

The Supreme Court DENIED the petitions and AFFIRMED the Court of Appeals’ decisions. The one-time bonuses did not ripen into a company practice enforceable as a matter of right. The bonuses were granted as acts of generosity from different managements, contingent upon business performance and management prerogative, not out of any legal obligation. The nomenclature “one-time” and the varying amounts, computation bases, and recipients each year negated any finding of regularity or consistency necessary to establish a company practice. The grant was not based on a collective bargaining agreement or any contract. The Court emphasized that a bonus is generally a gratuity or an act of liberality, and to be considered part of wages, it must be granted with such regularity as to be considered part of regular compensation. The circumstances here showed the bonuses were given only when the company was profitable and under specific management approvals, thus remaining discretionary.