G.R. No. 164060 . June 15, 2007.
FACULTY ASSOCIATION OF MAPUA INSTITUTE OF TECHNOLOGY (FAMIT), petitioner, vs. HON. COURT OF APPEALS and MAPUA INSTITUTE OF TECHNOLOGY, respondents.

FACTS

The parties entered into a 2001 Collective Bargaining Agreement (CBA) which incorporated a new faculty ranking system for college faculty, specifying in Article V, Section 8 that “there shall be no diminution in the existing rank and the policy ‘same rank, same pay’ shall apply.” Annexes to the CBA detailed a 19-rank structure with corresponding point ranges and pay rates. Subsequently, Mapua Institute of Technology (MIT) sought to amend these annexes, proposing to replace them with a 23-rank instrument and to correct alleged inadvertent omissions in the point range data. FAMIT rejected this as a unilateral alteration violating the ratified CBA.
A separate dispute arose concerning high school faculty compensation. The CBA’s Article VI, Section 2 stipulated salary increases based on a “rate per load.” MIT unilaterally adopted a new formula factoring in actual teaching hours, arguing it was a fair interpretation. FAMIT opposed this change, contending it deviated from the agreed “rate per load” basis and past practice. The disputes were elevated to the Panel of Voluntary Arbitrators, which ruled in FAMIT’s favor, ordering MIT to implement the original 19-rank system and the “rate per load” formula.

ISSUE

Whether MIT could unilaterally alter the faculty ranking system and the salary computation formula after the CBA’s execution.

RULING

The Supreme Court ruled in favor of FAMIT, reversing the Court of Appeals. A CBA is a binding contract, and its provisions must be respected as the law between the parties. MIT’s proposed modifications to the college faculty ranking—changing the agreed 19-rank system to 23 ranks and altering the point ranges—constituted a unilateral change violating the CBA’s explicit terms and the principle of “no diminution in rank.” The Court emphasized that such post-execution alterations are impermissible without mutual consent.
Regarding high school faculty pay, the CBA clearly specified compensation based on a “rate per load.” MIT’s unilateral shift to an hourly rate formula was a substantive change not sanctioned by the agreement. In interpreting labor contracts and laws, doubts must be resolved in favor of labor. The Court found MIT’s actions constituted a violation of the CBA’s terms and the Labor Code. Consequently, the decision of the Voluntary Arbitrators was reinstated, declaring MIT’s unilateral changes null and void.