SC Upholds NLRC Authority in Guagua National Colleges Labor Dispute

Manila: The Supreme Court (SC) upheld the authority of the National Labor Relations Commission (NLRC) to execute the terms of Collective Bargaining Agreements (CBA) in cases involving unfair labor practices.

According to Philippines News Agency, in a decision made public on Monday, the SC Third Division upheld the NLRC order directing the Guagua National Colleges (GNC) to pay its employees the agreed economic benefits, but adjusted the computation. The case arose from negotiations in 2009 to renew the five-year CBA between GNC and its unions.

Although GNC agreed to provide benefits such as a rice subsidy, loyalty pay, and clothing allowance, it delayed signing the draft CBA. Frustrated, the unions filed a notice of strike, accusing GNC of acting in bad faith and serious CBA violations. To prevent the strike, the Department of Labor and Employment stepped in and referred the case to the NLRC for compulsory arbitration.

The NLRC ruled that GNC bargained in bad faith, which is an unfair labor practice. It also declared the final CBA draft as the parties' agreement. NLRC ordered GNC to pay its employees the agreed benefits covering 2009 to 2017. However, GNC questioned the order directing them to pay, arguing that only voluntary arbitrators -- not the NLRC -- had the power to enforce the CBA terms.

The Court of Appeals (CA) upheld the NLRC's order. The SC agreed with the CA and clarified that while voluntary arbitrators generally handle CBA implementation, the law authorizes the NLRC to enforce CBA provisions when gross violations are involved.

'In this case, the NLRC determined that GNC engaged in unfair labor practice by bargaining in bad faith. It also declared the final CBA draft to be the official agreement between the two parties,' the court said. 'After reviewing the CBA, the NLRC was best positioned to enforce it. Sending the case to voluntary arbitrators for implementation would only cause delays, increase the likelihood of multiple lawsuits, and prolong the resolution of rights and obligations between the parties,' the SC said.

The SC also ruled that the computation of benefits was incorrect and that GNC should exclude the signing bonus and cover only the five-year CBA term (2009 to 2014).