G.R. No. 76988 . January 31, 1989.
GENERAL RUBBER AND FOOTWEAR CORPORATION, petitioner, vs. THE HON. FRANKLIN DRILON IN HIS CAPACITY AS THE MINISTER OF LABOR & EMPLOYMENT and THE GENERAL RUBBER WORKERS’ UNION-NATU, respondents.

FACTS

Petitioner General Rubber and Footwear Corporation applied for exemption from Wage Order No. 6, which mandated wage and allowance increases. The National Wages Council denied the application in a final order dated March 4, 1985, directing petitioner to pay the increases effective November 1, 1984. Petitioner filed a motion for reconsideration. Subsequently, a strike was declared by some union members. To settle the strike, petitioner and a union leader entered into a Return-to-Work Agreement on May 28, 1985. Article 4 of the Agreement stipulated that the company would implement the wage order effective May 30, 1985, and withdraw its pending motion for reconsideration. In consideration, the union, its officers, and members agreed to waive any claim for differential pay for the period from November 1, 1984, to May 29, 1985. This agreement was later ratified by 268 union members.
However, approximately 100 union members refused to sign the ratification instrument. These minority members, through the union, filed a motion for a writ of execution to enforce the Wages Council’s final order for the payment of the accrued wage differentials. The Regional Director initially granted execution but later reversed himself, holding that the majority ratification bound all members. On appeal, the Minister of Labor set aside the reversal, ordering the issuance of a writ of execution to enforce the differential pay for the 100 non-ratifying workers.

ISSUE

Whether union members who did not personally ratify a waiver of accrued wage differentials are bound by the majority ratification of a Return-to-Work Agreement containing such a waiver.

RULING

No. The Supreme Court dismissed the petition, upholding the Minister of Labor’s decision. The legal logic is anchored on the personal nature of accrued monetary claims. The Court, reiterating the doctrine established in Kaisahan ng Manggagawa sa La Campana v. Sarmiento, ruled that accrued money claims, such as wage differentials, are personal rights. A waiver of such vested rights to be legally effective requires the individual consent of each worker concerned. The collective action or majority vote of the union membership cannot validly compromise or extinguish the personal claims of dissenting minority members.
The Court emphasized that neither the union officers nor the majority of members possessed the authority to waive the accrued rights of the minority. This principle serves as a crucial protective measure for workers, safeguarding them not only from employers but also from potential overreach by their own union leadership or from making imprudent decisions under economic pressure. Consequently, Article 4 of the Return-to-Work Agreement, containing the waiver, was unenforceable against the 100 non-consenting members. As petitioner had withdrawn its motion for reconsideration, the Wages Council’s order became final and executory as to these workers, making the issuance of a writ of execution for the enforcement of their differential pay proper and lawful.