G.R. No. 198783 ; April 15, 2013
ROYAL PLANT WORKERS UNION, Petitioner, vs. COCA-COLA BOTTLERS PHILIPPINES, INC.-CEBU PLANT, Respondent.

FACTS

Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation with a bottling plant in Cebu City. The bottling operators, all male and members of the Royal Plant Workers Union (ROPWU), work in shifts. In 1974, chairs were provided to operators of Bottling Line 2 upon their request, and in 1988, chairs were also provided to operators of Bottling Line 1. In September 2008, CCBPI removed the chairs pursuant to a national directive aligned with its “I Operate, I Maintain, I Clean” program. The company reasoned that the program required operators to constantly move to check machinery, making chairs unnecessary, and that removal would prevent sleeping on duty, thereby avoiding injuries and hampering efficient operations. The Union contested the removal through the CBA’s grievance machinery. After a deadlock and failed conciliation, the parties submitted the sole issue of the validity of the chair removal to voluntary arbitration. The Arbitration Committee ruled in favor of the Union, declaring the removal invalid and ordering the restoration of the chairs, finding that their use for 34 and 20 years, respectively, constituted a company practice and benefit that could not be unilaterally withdrawn under Article 100 of the Labor Code, and that CCBPI failed to present evidence of sleeping incidents or accidents. CCBPI appealed to the Court of Appeals, which reversed the Arbitration Committee, ruling that the removal was a valid exercise of management prerogative, motivated by good intentions for safety and efficiency.

ISSUE

Whether the removal of the chairs provided to the bottling operators constitutes a valid exercise of management prerogative or an invalid diminution of benefits under Article 100 of the Labor Code.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the Decision of the Voluntary Arbitration Panel. The removal of the chairs was declared invalid, and CCBPI was ordered to restore them.
The Court held that the provision of chairs for 34 years (Bottling Line 2) and 20 years (Bottling Line 1) had ripened into a company practice, which under Article 100 of the Labor Code, constitutes a benefit that cannot be unilaterally withdrawn, diminished, or eliminated by the employer. Jurisprudence does not require a specific minimum number of years for a practice to be considered a benefit; its longevity and consistency are key. The Court found that the chairs were provided upon the employees’ request and were enjoyed without issue for decades, during which CCBPI did not present evidence of any accident, injury, or specific instances of sleeping on duty attributable to the chairs. The company’s belated safety concern, after such a long period, was deemed insufficient to override the established benefit. While management has prerogatives, these must be exercised in good faith and without violating the law or a collective bargaining agreement. Here, the removal constituted a diminution of a benefit enjoyed by the employees at the time of the Labor Code’s promulgation, which is expressly prohibited. The Court emphasized that the State’s policy is to assure just and humane conditions of work, and the long-standing practice of providing chairs contributed to such conditions. Therefore, CCBPI’s action was invalid.