GR 89007; (March, 1991) (Digest)
G.R. No. 89007 ; March 11, 1991
JUAN C. CARDONA, representing all former employees of the COMMERCIAL BANK & TRUST COMPANY (COMTRUST), petitioners, vs. THE HON. NATIONAL LABOR RELATIONS COMMISSION and THE BANK OF THE PHILIPPINE ISLANDS (BPI), respondents.
FACTS
Petitioner Juan C. Cardona, former President of the Comtrust Employees Union (CEU), filed a complaint in 1988 on behalf of former Commercial Bank and Trust Company (CBTC) employees absorbed by the Bank of the Philippine Islands (BPI) following their 1980 merger. The complaint sought wage differentials, alleging a wage distortion because the absorbed employees received lower salaries than original BPI employees. This claim was based on a proposed P340.00 monthly increase from aborted CBA negotiations between CBTC and CEU in 1980, which were discontinued due to the merger talks.
The Labor Arbiter granted the claim, ordering BPI to pay the differentials. However, the National Labor Relations Commission (NLRC) reversed this decision. The NLRC found no evidence of wage distortion, noted that BPI had aligned the benefits of absorbed employees by 1981, and ruled that the aborted CBA negotiations created no binding obligation for BPI as the surviving corporation.
ISSUE
The core issues are: (1) whether a wage distortion existed between original BPI employees and absorbed ex-CBTC employees; (2) whether the absorbed employees are entitled to salary differentials based on the deadlocked CBA negotiations; and (3) whether the claim has prescribed.
RULING
The Supreme Court denied the petition and sustained the NLRC resolution. On the factual question of wage distortion, the Court upheld the NLRC’s finding that no such disparity existed, emphasizing that such factual determinations are generally final and binding when supported by substantial evidence. The NLRC record showed BPI had fulfilled its pre-merger commitment to harmonize employment terms, granting ex-CBTC employees the same wage increase and benefits as original BPI staff by early 1981.
Legally, the Court ruled that the aborted CBA negotiations between CBTC and CEU did not create any enforceable obligation for BPI. Since no CBA was perfected prior to the merger, there was no contractual liability for BPI to assume, notwithstanding the general succession of liabilities under the Corporation Code. The absorbed employees, having accepted the aligned benefits for years, could not resurrect a claim based on uncompleted negotiations. Consequently, the Court found no grave abuse of discretion by the NLRC and deemed it unnecessary to rule on the issue of prescription.