GR 110007; (October, 1996) (Digest)
G.R. No. 110007 October 18, 1996
Holy Cross of Davao College, Inc. vs. Hon. Jerome Joaquin, in his capacity as Voluntary Arbitrator, and Holy Cross of Davao College Union-KAMAPI.
FACTS
Holy Cross of Davao College and the Holy Cross of Davao College Union-KAMAPI entered into a Collective Bargaining Agreement effective from June 1, 1986 to May 31, 1989. Before its expiration, KAMAPI requested a two-month extension until July 31, 1989, which the school granted. Internal union strife led to a rival union’s petition for a certification election, a dispute ultimately resolved by the Supreme Court in favor of KAMAPI. After this resolution, KAMAPI submitted revised bargaining proposals. Holy Cross refused to negotiate, arguing it needed a “definitive ruling” on the interpretation of the old CBA’s automatic renewal clause, which provided for a three-year extension if the parties failed to agree on renewal. The school also unilaterally stopped deducting union dues and agency fees. The dispute was submitted to voluntary arbitration.
ISSUE
The primary issues were whether the CBA was automatically renewed for three years upon its expiration and whether Holy Cross committed unfair labor practice by refusing to bargain.
RULING
The Supreme Court ruled that the CBA was not automatically renewed. The automatic renewal clause was intended as a “hold-over” provision to maintain industrial peace while negotiations for a new agreement were ongoing, not to impose a new three-year term without mutual consent. The Court found that KAMAPI’s request for an extension and subsequent submission of proposals constituted a timely notice to negotiate, preventing automatic renewal. However, the Court affirmed the voluntary arbitrator’s finding that Holy Cross committed unfair labor practice by refusing to bargain collectively. The school’s demand for a definitive ruling on the CBA clause was a mere pretext to avoid its duty to negotiate in good faith with the certified bargaining agent. The unilateral cessation of check-off deductions for union dues and agency fees, a benefit derived from the CBA, further evidenced bad faith. The order for the school to pay equivalent uncollected dues was nullified, but the order to negotiate in good faith was upheld.