GR 81144; (May, 1990) (Digest)
G.R. No. 81144, May 7, 1990
Meycauayan College, petitioner, vs. Honorable Franklin M. Drilon, in his capacity as Secretary of the Department of Labor and Employment and Meycauayan College Faculty and Personnel Association (MCFPA), respondents.
FACTS
Petitioner Meycauayan College and the respondent union entered into a Collective Bargaining Agreement (CBA) for 1983-1986, which included a specific salary scale. During the CBA’s lifetime, several Presidential Decrees and Wage Orders mandating salary and allowance increases were issued and implemented by the college. The union members received all these statutory increases. In 1987, a new union president discovered that the specific, higher salary rates stipulated in Article IV of the CBA had not been implemented by the college. The union filed a notice of strike for unfair labor practice based on this violation.
The Secretary of Labor assumed jurisdiction over the ensuing strike. The Regional Director found that while the college complied with the legal wage increases, it failed to implement the contractual salary scale in the CBA, resulting in a salary differential for covered employees. The Secretary of Labor affirmed this finding and ordered the college to pay the differentials.
ISSUE
Whether the employer’s compliance with statutory wage increases precludes employees from claiming the higher salary differentials provided under their Collective Bargaining Agreement.
RULING
No. The Supreme Court affirmed the Secretary of Labor’s decision, ruling that compliance with statutory wage orders does not absolve an employer from its contractual obligations under a CBA. The legal increases and the CBA stipulations are distinct and separate obligations. The law sets a mandatory floor for wages, but a CBA represents a negotiated contract for better terms and conditions of employment. The employer must fulfill both duties concurrently.
The Court rejected the petitioner’s argument that the statutory increases should be credited against the CBA rates. To allow such crediting would nullify the purpose of collective bargaining, which is to secure benefits over and above the legal minimums. The CBA rates are fixed amounts, and the statutory increases are additional entitlements that do not offset the agreed contractual scale. Furthermore, the Court held that the claim was not barred by prescription, as the union discovered the violation only in 1987 and immediately acted. The Secretary of Labor also properly exercised jurisdiction, as the claim for differentials arose from an unfair labor practice (violation of the CBA), not a mere money claim.