GR L 53337; (June, 1984) (Digest)
G.R. No. L-53337 June 29, 1984
American Wire & Cable Workers Union (TUPAS), petitioner, vs. The National Labor Relations Commission and American Wire & Cable Co., Inc., respondents.
FACTS
Petitioner Union and respondent Company entered into a Collective Bargaining Agreement (CBA) effective May 1, 1976, which provided for a three-stage wage increase: 20% for the first year, 10% for the second year, and 10% for the third year. The first-year increase was implemented. During the CBA’s second year, Presidential Decree No. 1123 was enacted, mandating a P60.00 increase in the Emergency Cost of Living Allowance (ECOLA) effective May 1, 1977.
Respondent Company, while granting the CBA-stipulated 10% second-year increase, credited this amount against the P60.00 ECOLA mandated by P.D. 1123, offering to pay only the difference. It claimed exemption under paragraph (k), Section 1 of the Rules Implementing P.D. 1123, which exempted employers who had granted at least a P60.00 monthly wage increase on or after January 1, 1977. The Labor Arbiter and the NLRC sustained this position, dismissing the Union’s complaint which sought to receive both the CBA increase and the full P.D. 1123 allowance.
ISSUE
Whether the National Labor Relations Commission acted with grave abuse of discretion in upholding the respondent Company’s exemption from paying the full P60.00 ECOLA under P.D. 1123 based on paragraph (k) of its Implementing Rules.
RULING
The Supreme Court granted the petition, ruling that the NLRC committed grave abuse of discretion. The Court declared paragraph (k), Section 1 of the Rules Implementing P.D. 1123 void for being in excess of the statutory authority granted to the Secretary of Labor. The authority under P.D. 1123’s Section 4 was limited to issuing rules for implementation and exempting distressed employers. The inclusion of an exemption for employers who had granted wage increases was a substantive addition not authorized by the decree itself, thereby contravening the law it sought to implement.
Consequently, with the exemption clause voided, the respondent Company had no legal basis to credit the CBA wage increase against the statutory ECOLA. Following the constitutional mandate for protection of labor and the rule that all doubts in labor law implementation are resolved in favor of workers, the Court ordered the Company to pay the covered employees both the 10% CBA wage increase and the full P60.00 ECOLA under P.D. 1123. The decision of the NLRC was set aside.