GR L 19017; (December, 1963) (Digest)
G.R. No. L-19017 December 27, 1963
NATIONAL BREWERY AND ALLIED INDUSTRIES LABOR UNION OF THE PHILIPPINES (PAFLU), plaintiff-appellant, vs. SAN MIGUEL BREWERY, INC., defendant-appellee.
FACTS
The National Brewery and Allied Industries Labor Union (PAFLU) and San Miguel Brewery, Inc. entered into a collective bargaining agreement (CBA) effective for three years. Section 7, Article VII of the CBA stipulated that the company agreed to pay the basic daily rates of workers within the bargaining unit who participate in the Labor Day parade on May 1st of every year. On May 1, 1960, about 600 union members participated in a parade. The union demanded payment of their basic wages for that day, amounting to P3,900.00 in total, but the company refused.
The union filed a complaint in the Court of First Instance of Manila to compel payment and sought additional damages. The company, in its answer, raised affirmative defenses, arguing that the union was not the real party in interest, as the right to recover the one-day wage was personal to the individual members. It also contested the court’s jurisdiction, contending that the individual claims, if calculated separately, would fall below the jurisdictional amount for the court of first instance. The trial court ordered the union to amend its complaint to include the 600 members as parties plaintiff and to state each individual claim. Upon the union’s failure to comply within the given period, the court dismissed the complaint.
ISSUE
Whether the labor union, as a party to the collective bargaining agreement, is the proper party to institute the action for the enforcement of the wage benefit stipulated therein for its members, or whether the individual members are the indispensable real parties in interest.
RULING
The Supreme Court reversed the trial court’s orders and held that the union is the proper party to sue. The legal logic is anchored on the nature and source of the right being enforced. The Court distinguished between a claim for ordinary wages earned from services rendered, where the employee is the real party in interest, and a claim for a benefit that arises solely from a collective bargaining agreement. The right to payment for parade participation did not pre-exist; it was created by and flowed directly from the CBA negotiated by the union itself.
The union, as the contracting party that secured this benefit for its members, is deemed a party in whose name the contract was made for the benefit of another. Applying Section 3, Rule 3 of the Rules of Court, a party who makes a contract for the benefit of another may sue without joining the beneficiary. Therefore, the union had the personality to sue on the CBA provision. Joining over 600 individual members was deemed cumbersome and unnecessary. Consequently, the trial court had jurisdiction based on the total amount claimed in the complaint filed by the union. The case was remanded for further proceedings.