Metrobank Union v. NLRC

 Metrobank Union v. NLRC

G.R. No. 102636

September 10, 1993

DOCTRINE: All doubts in the interpretation and implementation of Labor Laws must be resolved in favor of labor. The intentions of the parties, whether the benefits under a CBA should be equated with those granted by law or not, unless there are compelling reasons otherwise, must prevail and be given effect.  

FACTS: 

The bank entered into a CBA with the MBTCEU, granting a monthly P900 wage increase effective 01 January 1989, P600 wage increase effective 01 January 1990, and P200 wage increase effective 01 January 1991. The MBTCEU had also bargained for the inclusion of probationary employees in the list but the bank had adamantly refused to accede thereto. Only regular employees were given the increase. RA 6727, “an act to rationalize wage policy determination by establishing the mechanism and proper standards therefor,… fixing new wage rates…” The provisions state that the minimum wage rates shall be increased by P25 per day provided, that those already receiving above the minimum up to P100 shall also receive an increase of P25 per day. The bank refused to give the same increase to its regular employees who were receiving more than P100 per day and recipients of the P900 CBA increase. MBTCEU contended that there emerged a salary gap. It sought from the bank the correction of the distortion in pay. They agreed to refer the issue to the NLRC. The labor arbiter directed the bank to restore to complainants and their members the P900 CBA wage gap they used to enjoy over non-regular employees. The bank appealed to the NLRC which reversed the LA’s decision. The MBTCEU filed an MR but it was denied so it filed this petition for certiorari. A formula for wage distortion was expressed in the dissenting opinion of Commissioner Bonto-Perez.

ISSUE: 

Whether or not the NLRC acted with grave abuse of discretion when it refused to acknowledge the existence of a wage distortion.

HELD: 

Yes. The “intentional quantitative differences” in wage among employees of the bank has been set by the CBA to about P900 per month as of 01 January 1989. It is intentional as it has been arrived at through the collective bargaining process to which the parties are thereby concluded. The Solicitor General emphasized that the intention of the parties, whether the benefits under a collective bargaining agreement should be equated with those granted by law or not, unless there are compelling reasons otherwise, must prevail and be given effect. In keeping then with the intendment of the law and the agreement of the parties themselves, along with the often repeated rule that all doubts in the interpretation and implementation of labor laws should be resolved in favor of labor, we must approximate an acceptable quantitative difference between and among the CBA agreed work levels. We are also of the view that giving the employees and across-the-board increase of P750 may not be conducive to the policy of encouraging “employers to grant wage and allowance increases to their employees higher than the minimum rates of increases prescribed by statute or administrative regulation,” particularly in this case where both RA 6727 and the CBA allow a credit for voluntary compliance.

As the Court in Apex Mining Company v. NLRC pointed out, “to compel employers simply to add on legislated increases in salaries or allowances without regard to what is already being paid, would be to penalize employers who grant their workers more than the statutorily prescribed minimum rates of increases. Clearly, this would be counter-productive so far as securing the interests of labor is concerned.” We find the formula suggested then by Commissioner Bonto-Perez, which has also been the standard considered by the Regional Tripartite Wages and Productivity Commission for the correction of pay scale structures in cases of wage distortion, to well be the appropriate measure to balance the respective contentions of the parties in this instance. We also view it as being just and equitable.