G.R. No. 218010 , February 6, 2023
FERNAND O. MATERNAL, ET AL., PETITIONERS, VS. COCA-COLA BOTTLERS PHILS., INC. (NOW KNOWN AS COCA-COLA FEMSA PHILS., INC.), RESPONDENT.

FACTS

Petitioners were employees of respondent Coca-Cola Bottlers Phils., Inc. They received annual bonuses from the company in 1997 and from 2001 to 2007. The bonuses were given under various names such as “One-Time Grant,” “One-Time Economic Assistance,” “One-Time Gift,” “One-Time Christmas Gift,” and “One-Time Transition Bonus,” with amounts based on a percentage of basic salary or a fixed sum. In 2007, respondent announced that starting 2008, all bonuses (except 13th month pay) would be based on individual or department performance. However, no performance-based bonuses were released in 2008 and 2009. Petitioners filed a claim for payment of the annual bonus. The Labor Arbiter ruled in favor of the petitioners, finding the annual bonus had ripened into a company practice and awarded yearly bonuses from 2008 to 2010. The National Labor Relations Commission (NLRC) affirmed but modified the award amount. The Court of Appeals reversed the labor tribunals, declaring their decisions void. The ponencia (main decision) upheld the Court of Appeals.

ISSUE

Whether the annual bonus granted by the respondent to its employees from 1997 to 2007 had ripened into a company practice, making it a demandable right.

RULING

The dissenting opinion of Justice Leonen argues that the annual bonus had ripened into a company practice and should be considered a demandable part of the employees’ compensation. The dissent disagrees with the ponencia’s affirmation of the Court of Appeals’ reversal of the labor tribunals. It cites jurisprudence stating that a bonus becomes part of wages if it is additional compensation promised and agreed to be given without conditions. To be considered a company practice, the giving of benefits must be done over a long period, consistently and deliberately. The dissent points out that the facts are undisputed: petitioners received annual bonuses for at least seven years (1997, 2001-2007). It argues that the length and regularity of the grant over this significant period, without being contingent on specific performance conditions for the employees, substantiates that it had become a consistent and deliberate company practice. Therefore, the dissent concludes that the Petition should be granted, and the bonuses for 2008 to 2010 should be paid.