GR 220383; (July, 2017) (Digest)
G.R. No. 220383, July 5, 2017
SONEDCO WORKERS FREE LABOR UNION (SWOFLU), ET AL., Petitioners, vs. UNIVERSAL ROBINA CORPORATION, SUGAR DIVISION-SOUTHERN NEGROS DEVELOPMENT CORPORATION (SONEDCO), Respondents.
FACTS
Petitioners, members of SONEDCO Workers Free Labor Union, filed an unfair labor practice complaint against their employer, URC-SONEDCO. In 2007 and 2008, while no Collective Bargaining Agreement (CBA) was in effect, the company offered a daily wage increase of ₱16.00 each year. To receive these increases, employees were required to sign a waiver stipulating that any subsequently negotiated CBA would only become effective the following calendar year. Petitioners refused to sign these waivers, viewing them as an interference with their right to collective bargaining, and consequently did not receive the wage increases totaling ₱32.00 per day.
The National Labor Relations Commission and the Court of Appeals found URC-SONEDCO not guilty of unfair labor practice but ordered it to grant petitioners the 2007 and 2008 wage increases. However, they denied the claim for a continuing ₱32.00 daily wage increase from 2009 onwards. This Court, in a prior Decision, reversed the lower tribunals and found URC-SONEDCO guilty of unfair labor practice for bargaining in bad faith, affirming the grant of the 2007 and 2008 increases but similarly denying the 2009 onward claim. Petitioners filed this Motion for Partial Reconsideration, seeking the continuing wage increase from January 1, 2009.
ISSUE
Whether petitioners are entitled to a continuing daily wage increase of ₱32.00 from January 1, 2009, as a consequence of the employer’s unfair labor practice.
RULING
No. The Supreme Court denied the motion and upheld its prior ruling. The legal logic is clear: while the wage increases for 2007 and 2008 were awarded as a direct remedy for the unfair labor practice committed by URC-SONEDCO in withholding them via coercive waivers, the claim for a continuing increase from 2009 onward operates under a different legal regime. Beginning January 1, 2009, a new CBA governed the relationship between the union and the management. Benefits not stipulated in a CBA are generally not demandable.
The Court emphasized that the proper recourse for securing the wage increase beyond 2008 was to negotiate for its inclusion in the 2009 CBA. The finding of unfair labor practice for the 2007-2008 acts does not automatically translate into a perpetual entitlement to a unilateral wage adjustment. To grant the continuing increase would unjustly extend a corrective remedy for past violations into a future period already regulated by a consensual bargaining agreement. The law encourages collective bargaining as the primary mechanism for setting terms of employment, and the Court will not impose terms that the parties themselves did not agree upon in their CBA.