GR L 30241; (June, 1972) (Digest)
G.R. No. L-30241 June 30, 1972
MACTAN WORKERS UNION and TOMAS FERRER, as President thereof, plaintiffs-appellees, vs. DON RAMON ABOITIZ, President, CEBU SHIPYARD & ENGINEERING WORKS, INC.; EDDIE LIM, as Treasurer; JESUS DIAGO, Superintendent of the aforesaid corporation; WILFREDO VIRAY, as Resident Manager of the Shipyard & Engineering Works, Inc.; and the CEBU SHIPYARD & ENGINEERING WORKS, INC., defendants-appellees; ASSOCIATED LABOR UNION, intervenor-appellant.
FACTS
The Cebu Shipyard & Engineering Works, Inc. entered into a Collective Bargaining Agreement (CBA) with the Associated Labor Union (ALU) as the exclusive bargaining representative. The CBA included a profit-sharing bonus for employees. The company delivered the second installment of the 1965 bonus to ALU for distribution. Seventy-two employees who were members of the rival Mactan Workers Union (MWU) refused to collect their shares from ALU’s office. Following the CBA provision, ALU returned the unclaimed amount to the company after 60 days and advised the company not to pay the MWU members directly. The company then deposited the money with the Labor Administrator.
ISSUE
Whether the MWU members are entitled to receive their profit-sharing bonus directly from the company or through the ALU, and whether procedural obstacles bar their claim.
RULING
The Supreme Court affirmed the lower court’s decision, ordering the company to deliver the bonus to ALU for distribution to the MWU members. The Court held that the claim is meritorious and not barred by procedural doctrines. The legal logic is anchored on the principle that a CBA creates reciprocal obligations enforceable as a contract under the Civil Code. The MWU members, as employees of the company, are third-party beneficiaries of the CBA between the company and ALU. Their right to the bonus is vested and cannot be forfeited by their refusal to collect from ALU, as such refusal was not a waiver of their right but an assertion of their union affiliation. The Court emphasized that technicalities should not obstruct substantive rights, especially in labor cases where the policy is to ensure justice according to law. The company’s duty to pay the bonus remains, and ALU, as the exclusive bargaining agent, is obligated under the CBA to distribute the funds to all entitled employees, regardless of union membership.