G.R. No. 109383 June 15, 1998
MANILA CENTRAL LINE CORPORATION, petitioner, vs. MANILA CENTRAL LINE FREE WORKERS UNION-NATIONAL FEDERATION OF LABOR and the NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

The case arose from a collective bargaining deadlock between petitioner Manila Central Line Corporation and respondent Manila Central Line Free Workers Union-National Federation of Labor after their CBA expired on March 15, 1989. Conciliation efforts before the National Conciliation and Mediation Board failed. On February 9, 1990, the union filed a “Petition for Compulsory Arbitration” with the NLRC Arbitration Branch. At the initial hearing, both parties declared that conciliation had terminated and expressed their desire to submit the case for compulsory arbitration. They submitted position papers and proposals, indicating agreed portions and leaving the rest for arbitration. Labor Arbiter Donato G. Quinto, Jr. rendered a decision on September 28, 1990, directing the parties to execute a new five-year CBA retroactive to March 15, 1989. Petitioner appealed to the NLRC, which dismissed the appeal and denied reconsideration, prompting this petition for certiorari.

ISSUE

The primary issues were: (1) Whether the Labor Arbiter had jurisdiction to act as a voluntary arbitrator; (2) Whether the factual findings on economic provisions (commission rates, incentive pay, salaries, and signing bonus) were supported by evidence; (3) Whether the retroactive effectivity of the CBA to March 15, 1989 was valid; and (4) Whether the Labor Arbiter disregarded provisions agreed upon by the parties.

RULING

The Supreme Court dismissed the petition for lack of merit. On jurisdiction, the Court held that although the union’s petition was for “compulsory arbitration,” petitioner’s agreement to submit the matter for arbitration effectively made it a voluntary arbitration. There is no prohibition against labor arbiters acting as voluntary arbitrators by party agreement. Petitioner was estopped from questioning jurisdiction after agreeing to arbitration and only raising it post-decision. On factual findings, the Court ruled that findings of the Labor Arbiter and NLRC are binding and final when substantially supported by evidence, which they were, as both agencies exhaustively discussed the evidence, including the company’s financial claims. The Labor Arbiter’s decision on commission rates, incentive pay, and wage increases was a reasonable resolution of the deadlock. On the signing bonus, the Court found it was part of the arbitrated economic package and not a gratuity. On retroactive effectivity, the Court upheld the Labor Arbiter’s authority to determine the CBA’s effectivity as part of the arbitrated issues, noting it is standard practice for renewed CBAs to be retroactive to the expiry of the old one. Finally, the Court dismissed the claim that the Labor Arbiter disregarded agreed provisions for lack of specification.