CALTEX REFINERY EMPLOYEES ASSOCIATION v. BRILLANTES, G.R. No.

123782

Facts:

Anticipating the expiration of their CBA on July 31, 1995, Caltex Refinery Employees Association
(petitioner) and Caltex (Philippines), Inc. (private respondent), negotiated the terms and conditions of
employment to be contained in a new CBA. Some items in the new CBA were amicably arrived at and
agreed upon, but others were unresolved. On July 24, 1995, after several failed meetings, petitioner filed
a notice of strike. In an Order dated August 22, 1995, public respondent (Hon. Brillantes) assume
jurisdiction over the entire labor dispute.

In defiance of the Order expressly restraining any strike or lockout, petitioner began a strike and
set up a picket in the premises of private respondent on August 25, 1995. In the course of the strike, public
respondent interceded and conducted several conciliation meetings between the contending parties.
Because of the strike, private respondent terminated the employment of some officers of petitioner
union. The public respondent, issued two more Orders on November 21, 1995 and January 16, 1996
disposing of the motions for reconsideration or clarification of both parties

Issue:

Whether or not the Honorable Secretary of Labor and Employment committed grave abuse of
discretion in resolving the instant labor dispute.

Held:

Other than the SOLE’s failure to rule on the issue of union security clause, he cannot be indicted
for grave abuse of discretion amounting to want or excess of jurisdiction. Basically, there is grave abuse
of discretion amounting to lack of jurisdiction where the respondent board, tribunal, or officer exercising
judicial functions exercised its judgment in a capricious, whimsical, arbitrary or despotic manner.

Petitioner’s claim of grave abuse of discretion is anchored on the simple fact that public
respondent adopted largely the proposals of private respondent. It should be understood that bargaining
is not equivalent to an adversarial litigation where rights and obligations are delineated and remedies
applied. It is simply a process of finding a reasonable solution to a conflict and harmonizing opposite
positions into a fair and reasonable compromise. In this case, it is possible that this Court, or some
members at least, may even agree with the wisdom of petitioner’s claims. But unless grave abuse of
discretion is cogently shown, this Court will refrain from using its extraordinary power of certiorari to
strike down decisions and orders of quasi-judicial officers specially tasked by law to settle administrative
questions and disputes.
P.I. MFG. INC. v. P.I. MFG. SUPERVISORS’ AND FOREMEN ASSOCIATION, G.R. No. 167217

Facts:

Petitioner is a domestic corporation engaged in the manufacture and sale of household

appliances. On the other hand, respondent PIMASUFA is an organization of petitioner’s supervisors and
foremen, joined in this case by its federation, the National Labor Union (NLU). On December 10, 1987,
the President signed into law Republic Act No. 6640 providing, among others, an increase in the
statutory minimum wage and salary rates of employees and workers in the private sector. Thereafter,
on December 18, 1987, petitioner and respondent PIMASUFA entered into a new Collective
Bargaining Agreement (1987 CBA) whereby the supervisors were granted an increase of P625.00 per
month and the foremen, P475.00 per month. The increases were made retroactive to May 12, 1987,
or prior to the passage of R.A. No. 6640, and every year thereafter until July 26, 1989. On January 26,
1989, respondents PIMASUFA and NLU filed a complaint with the Arbitration Branch of the National
Labor Relations Commission (NLRC), charging petitioner with violation of R.A. No. 6640. On March
19, 1990, the Labor Arbiter rendered his Decision in favor of respondents.
On appeal by petitioner, the NLRC, in its Resolution dated January 8, 1991, affirmed the Labor
Arbiter’s judgment. On July 21, 2004, the appellate court rendered its Decision affirming the Decision
of the NLRC with modification by raising the 13.5% wage increase to 18.5%.

Issue:

Whether or not the implementation of R.A. No. 6640 resulted in a wage distortion and whether
such distortion was cured or remedied by the 1987 CBA.

Held:
R.A. No. 6727, explicitly defines wage distortion as a situation where an increase in prescribed
wage rates results in the elimination or severe contraction of intentional quantitative differences in
wage or salary rates between and among employee groups in an establishment as to effectively
obliterate the distinctions embodied in such wage structure based on skills, length of service, or other
logical bases of differentiation. In this case, the Court of Appeals correctly ruled that a wage distortion
occurred due to the implementation of R.A. No. 6640. The numerical illustration submitted by
respondents shows such distortion.
However, while we find the presence of wage distortions, we are convinced that the same
were cured or remedied when respondent PIMASUFA entered into the 1987 CBA with petitioner after
the effectivity of R.A. No. 6640. The 1987 CBA increased the monthly salaries of the supervisors
by P625.00 and the foremen, by P475.00,effective May 12, 1987. These increases re-
established and broadened the gap, not only between the supervisors and the foremen, but also
between them and the rank-and-file employees. Interestingly, such gap as re-established by virtue of
the CBA is more than a substantial compliance with R.A. No. 6640.
At this juncture, it must be stressed that a CBA constitutes the law between the
parties when freely and voluntarily entered into. Here, it has not been shown that respondent
PIMASUFA was coerced or forced by petitioner to sign the 1987 CBA. All of its thirteen (13) officers
signed the CBA with the assistance of respondent NLU. They signed it fully aware of the passage of
R.A. No. 6640. Respondents cannot invoke the beneficial provisions of the 1987 CBA but disregard
the concessions it voluntary extended to petitioner. The goal of collective bargaining is the making of
agreements that will stabilize business conditions and fix fair standards of working conditions.