GR 62918; (August, 1989) (Digest)
G.R. No. 62918 August 23, 1989
FILIPINAS GOLF & COUNTRY CLUB INC., petitioner-appellant, vs. NATIONAL LABOR RELATIONS COMMISSION, PTGWO and LOCAL CHAPTER NO. 424, respondents-appellees.
FACTS
The case involves a dispute over wage increases under a Collective Bargaining Agreement (CBA) and statutory wage orders. Petitioner Filipinas Golf & Country Club, Inc. complied with Presidential Decree No. 1678 and Wage Order No. 1, which granted daily living allowance increases to non-agricultural workers. Subsequently, a compulsory arbitration decision resolved a CBA deadlock, awarding the employees a three-stage wage increase totaling P5.00 daily. The Labor Arbiter ordered execution for the CBA increases, and a garnishment was issued against the petitioner. Filipinas Golf executed the mandated CBA, which included a provision subjecting its terms to applicable decrees or legislation. It then moved for reconsideration, arguing that the statutory increases it had already given should be credited against its CBA obligations.
ISSUE
Whether the wage increases granted by the employer under PD 1678 and Wage Order No. 1 can be credited against the wage increases mandated under the Collective Bargaining Agreement.
RULING
The Supreme Court ruled in favor of the petitioner, reversing the NLRC. The legal logic is anchored on the clear and unambiguous creditability provisions of PD 1678 and Wage Order No. 1. These laws explicitly state that wage increases granted by employers, whether unilaterally or through a collective agreement, during specified periods shall be credited toward compliance with the statutory mandate. If the contractual increase is less than the legal requirement, the employer must pay the difference. The Court emphasized that these provisions refer to collective bargaining agreements without qualification, making no distinction between voluntarily negotiated agreements and those resulting from compulsory arbitration. Therefore, the Labor Arbiter and NLRC erred in creating a distinction not found in the law.
Furthermore, the Court applied the principle that the intention of the parties to the CBA governs the treatment of benefits. The executed CBA contained a clause subjecting its provisions to applicable legislation, demonstrating the parties’ manifest intent to treat legislated increases as creditable against the CBA increases. Jurisprudence establishes that whether benefits are cumulative depends on the parties’ agreement. Here, the creditability clauses in the laws and the CBA’s own condition converge to show that the obligations are not independent and cumulative. The statutory increases thus operate as compliance pro tanto with the CBA increases, obligating the employer only to pay any difference. The case was remanded to the NLRC for recomputation accordingly.