G.R. No. 165550, October 8, 2008
Standard Chartered Bank, petitioner, vs. Standard Chartered Bank Employees Union (SCBEU), respondent.

FACTS

Petitioner Standard Chartered Bank and respondent Standard Chartered Bank Employees Union entered into a Collective Bargaining Agreement (CBA) on August 25, 1998. The CBA provided for medical benefits, committing the Bank to “continue to cover all its employees with a group hospitalization and major surgical insurance plan including maternity benefits.” At the time of signing, the insurance plan in force was Group Policy No. P-1620 issued by Philamlife. After signing, the Bank changed its insurance provider from Philamlife to Maxicare. The Union charged the Bank with unfair labor practice before the DOLE, contesting the exclusion of outpatient medicine reimbursements for employees and maternity benefits for spouses of male employees in the new Maxicare policy. The Union presented evidence, including a letter from Philamlife and reimbursement documents, to prove employees had been enjoying outpatient medicine reimbursements. It also cited Schedule L of the CBA and employee affidavits to prove entitlement to spousal maternity benefits. The Bank argued there was no diminution of benefits, claiming outpatient medicine reimbursement was not expressly in the Philamlife policy and was instead covered by a separate medicine allowance in the CBA, and that maternity benefits were exclusive to female employees, with past practices being “malpractices.”
The DOLE initially ruled in favor of the Union on both benefits. Upon motions for reconsideration, it reversed its ruling on spousal maternity benefits but later reverted to its original position. The DOLE also clarified that outpatient benefits included medicine reimbursements. The Bank elevated the case to the Court of Appeals via certiorari. The CA dismissed the petition and affirmed the DOLE Orders. The CA held the basis for granting spousal maternity benefits was Schedule L of the CBA. It also found that a practice of granting outpatient medicine reimbursements had developed, which the Bank could not unilaterally withdraw.

ISSUE

1. Whether the spouses of male employees are entitled to maternity benefits.
2. Whether there is an established company practice of granting outpatient medicine reimbursements to employees.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals.
1. On the maternity benefits for spouses of male employees, the Court upheld the CA’s finding that Schedule L of the CBA was the basis for the grant. The Court found the Bank’s interpretation—that maternity benefits were exclusive to female employees—to be inconsistent with the explicit language of Schedule L, which stated that the maternity benefit was “P15,000 per pregnancy” without any qualification limiting it to female employees. The Court rejected the Bank’s argument that such an interpretation would lead to iniquitous results, stating that doubts in the interpretation of CBA provisions should be resolved in favor of labor. The Court also noted that while the CA found no established company practice of granting such benefits, its conclusion was sufficiently grounded on the CBA provision itself.
2. On the outpatient medicine reimbursements, the Court affirmed the findings of the DOLE and the CA that a practice had developed whereby employees were reimbursed for outpatient medicines under the old Philamlife plan. The Court cited the DOLE’s finding that the Philamlife policy allowed outpatient benefits as claims against maximum disablement and that the Bank had acknowledged, without disapproval, employees’ requests for such reimbursements. The Court held that this practice, which was not expressly stipulated in the CBA, had ripened into a company practice that the Bank could not unilaterally withdraw. The Court deferred to the factual findings of the labor tribunals and the CA, according them finality.