GR 127598; (February, 2000) (Digest)
G.R. No. 127598 February 22, 2000
MANILA ELECTRIC COMPANY, petitioner, vs. Hon. SECRETARY OF LABOR LEONARDO QUISUMBING and MERALCO EMPLOYEES AND WORKERS ASSOCIATION (MEWA), respondents.
FACTS
This case involves a motion for reconsideration of the Court’s January 27, 1999 Decision, which modified the Secretary of Labor’s arbitral awards in a collective bargaining dispute between MERALCO and its union, MEWA. The original Decision adjusted several economic and non-economic benefits, including reducing the wage increase from P2,200 to P1,900 and setting the retroactivity of the CBA from December 28, 1996. Dissatisfied parties, including alleged union members and a supervisors’ union, filed motions for intervention and reconsideration. They contested the modifications, particularly the wage award and the period of retroactivity.
ISSUE
The primary issues for resolution are: (1) the propriety of the wage increase amount granted in the January 27, 1999 Decision, and (2) the correctness of the retroactivity period of the arbitral awards.
RULING
The motions for reconsideration are denied. The Court modifies its previous wage award but affirms the retroactivity period. On the wage issue, petitioner’s argument that granting a P2,200 increase would force it to raise electricity rates is a non sequitur, as such rate increases require separate regulatory approval and do not automatically follow from wage hikes. The All Asia Capital report relied upon by the union is inadmissible under the rules of evidence for commercial lists, being a mere newspaper analysis without extrinsic proof of its accuracy or testimony to support it. However, considering petitioner’s admitted 1996 net income of P5.1 billion, which is close to the P5.7 billion figure used by the Secretary of Labor, the Court finds it equitable to adjust the wage increase from P1,900 to P2,000 for the two-year CBA period. This amount is consistent with historical wage patterns between rank-and-file and supervisory employees.
On retroactivity, the Court upholds its previous ruling setting the effectivity from December 28, 1996, the date of the Secretary’s second order resolving the dispute. Article 253-A of the Labor Code provides that arbitral awards shall be effective from the date of the award, not from the expiration of the previous CBA. This rule prevents undue retroactive impositions on employers and balances the interests of both parties. The period from December 28, 1996, to December 27, 1999, for a three-year CBA is therefore correct. Other challenged modifications, such as those on union security and contracting out, were sufficiently addressed in the original Decision and require no further discussion.