G.R. No. 101761 . March 24, 1993.
NATIONAL SUGAR REFINERIES CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and NBSR SUPERVISORY UNION, (PACIWU) TUCP, respondents.

FACTS

Petitioner National Sugar Refineries Corporation (NASUREFCO), a government-owned corporation, implemented a Job Evaluation (JE) Program on June 1, 1988, affecting all employees. The program re-evaluated positions, granted salary adjustments, and increased benefits. Prior to this, for about ten years, the members of the private respondent NBSR Supervisory Union (supervisory employees) were treated like rank-and-file and received overtime, rest day, and holiday pay. Under the JE Program, they were re-classified under levels S-5 to S-8, considered managerial staff for compensation, received an average 50% increase in basic pay, and were granted a P100.00 special allowance for rest day/holiday work in lieu of the previous overtime, rest day, and holiday pay. On June 20, 1990, the union members filed a complaint for non-payment of those benefits. The Executive Labor Arbiter ruled in favor of the union, ordering payment of the benefits and the difference from the P100.00 allowance. The National Labor Relations Commission (NLRC) affirmed, ruling the members were not managerial employees under Article 212(m) of the Labor Code and were thus entitled to the benefits. NASUREFCO filed this petition for certiorari, arguing the members are “officers or members of the managerial staff” under Article 82 of the Labor Code and thus exempt from entitlement to overtime, rest day, and holiday pay.

ISSUE

Whether supervisory employees, as defined in Article 212(m) of the Labor Code, should be considered as officers or members of the managerial staff under Article 82 of the Labor Code, and are therefore not entitled to overtime, rest day, and holiday pay.

RULING

The Supreme Court ruled in favor of the petitioner, NASUREFCO. The Court held that for the purpose of determining entitlement to overtime, rest day, and holiday pay, the applicable definition is that of “managerial employees” or “officers or members of a managerial staff” under Article 82, Book III of the Labor Code, and its implementing rules, not the definition under Article 212(m) which pertains to labor relations and the right to self-organization. The Court found that the members of the respondent union, based on their job descriptions, meet the conditions set forth in the implementing rules for being considered “officers or members of a managerial staff.” Their primary duties are directly related to management policies, they customarily exercise discretion and independent judgment, they directly assist managerial employees or execute specialized work under general supervision, and they do not devote more than 20% of their time to non-managerial tasks. Consequently, as members of the managerial staff, they are exempt from the coverage of Title I, Book III of the Labor Code on working conditions and are not entitled to overtime, rest day, and holiday pay. The Court further held that the JE Program was a valid exercise of management prerogative, implemented in good faith, and the acceptance of the promotion and increased benefits under the program precludes the employees from claiming the benefits of their former positions. The NLRC decision was annulled and set aside, and the union’s complaint was dismissed.