G.R. No. 155059 . April 29, 2005
AMERICAN WIRE AND CABLE DAILY RATED EMPLOYEES UNION, Petitioner, vs. AMERICAN WIRE AND CABLE CO., INC. and THE COURT OF APPEALS, Respondents.

FACTS

American Wire and Cable Co., Inc. is engaged in manufacturing wires and cables. Two unions exist within the company: the Monthly-Rated Union and the Daily-Rated Union (petitioner). The unions filed an original action for voluntary arbitration before the National Conciliation and Mediation Board (NCMB), alleging that the company unilaterally withdrew certain long-enjoyed benefits: a Service Award; a 35% premium pay for work on specified Holy Week and Christmas season days; a Christmas Party; and Promotional Increases for fifteen members who were assigned new job classifications. The company defended its actions, submitting a Revenues and Profitability Analysis for 1996-2000 to justify the withdrawal.
Voluntary Arbitrator Angel A. Ancheta rendered a decision in favor of the company, declaring it not guilty of violating Article 100 of the Labor Code (prohibition against diminution of benefits). The Arbitrator found the withdrawn benefits were not demandable as a matter of right and directed the company to grant the service award only at its discretion. The Court of Appeals affirmed the Arbitrator’s decision and subsequent order, prompting the petitioner union to elevate the case to the Supreme Court via a special civil action for certiorari.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming the Voluntary Arbitrator’s ruling that the company did not violate Article 100 of the Labor Code by unilaterally withdrawing the subject benefits and by not granting promotional increases.

RULING

The Supreme Court denied the petition and affirmed the assailed Court of Appeals Decision and Resolution. The Court found no grave abuse of discretion, as the appellate court correctly upheld the factual findings of the Voluntary Arbitrator. On the claim of diminution of benefits under Article 100, the Court reiterated that for a benefit to be considered a demandable right under the principle of “company practice,” it must be shown to have been granted over a long period of time and must be consistent and deliberate. The Voluntary Arbitrator found the grant of the 35% premium pay and Christmas party benefits to be irregular and contingent upon company profits and discretion, not a consistent practice. The Service Award was also determined to be a gratuitous gift dependent on profitability.
The Court emphasized that factual findings of quasi-judicial agencies like voluntary arbitrators, when supported by substantial evidence, are accorded respect and finality. It found no reason to disturb the Arbitrator’s conclusion that the company’s financial documents, though unaudited, sufficiently demonstrated a decline in profits justifying the withdrawal of these discretionary benefits. Regarding the promotional increases, the Court upheld the finding that the petitioner union failed to substantiate its claim that the reassignment of the fifteen employees constituted a promotion warranting a salary increase.