G.R. No. 156098; June 27, 2005
Holy Cross of Davao College, Inc., petitioner, vs. Holy Cross of Davao Faculty Union – KAMAPI, respondent.

FACTS

Holy Cross of Davao College, Inc. (petitioner) and the Holy Cross of Davao Faculty Union (respondent) executed a Collective Bargaining Agreement (CBA) in June 1997. Article XIII, Section 1 of the CBA provided a faculty development scholarship, entitling qualified academic personnel to a leave of absence with a grant-in-aid equivalent to their salary and allowance for studies promoting professional growth. In 1998, petitioner advertised a Monbusho scholarship from the Japanese Government. Faculty member Jean Legaspi applied, was selected, and requested the grant-in-aid benefit under the CBA.
Petitioner denied Legaspi’s request, citing its subsequently issued “Policy Statement and Guidelines for Trips Abroad,” which it claimed disqualified her. It granted her only a study leave without pay. The union filed a complaint, and the parties submitted the case to voluntary arbitration. The Voluntary Arbitrator ruled in favor of the union, ordering petitioner to pay Legaspi the grant-in-aid benefit. The Court of Appeals affirmed this decision, prompting petitioner to elevate the case to the Supreme Court via a petition for review.

ISSUE

Whether the subsequent “Policy Statement and Guidelines for Trips Abroad” issued by the petitioner can validly restrict or negate the grant-in-aid benefit expressly stipulated in the Collective Bargaining Agreement.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the principle that a CBA, once executed, is the law between the parties and its clear terms must be respected. The CBA provision was unambiguous: it granted the benefit for studies enhancing professional growth at institutions of higher learning. Legaspi’s Monbusho scholarship, which petitioner itself advertised, clearly fell within this scope as an in-service training for teachers aimed at professional improvement.
The Court held that unilaterally promulgated company policies or guidelines cannot supersede or diminish the obligations solemnly agreed upon in a CBA. Petitioner’s policy, issued after the CBA’s execution, was subordinate to the agreement. To allow such a policy to qualify or contradict the CBA would undermine the stability of collective bargaining. Since Legaspi complied with all substantive conditions under the CBA and bound herself to return to service, she was entitled to the benefit. The terms of the CBA, being clear, were to be implemented according to their literal meaning.