THE Supreme Court (SC) has upheld the authority of the National Labor Relations Commission (NLRC) to enforce the terms of Collective Bargaining Agreements (CBA) in cases involving unfair labor practices.
In a ruling promulgated on March 5, 2025 but only made public recently, the SC’s Third Division, through Associate Justice Japar Dimaampao, affirmed the legality of the NLRC order requiring the Guagua National Colleges (GNC) to pay its employees the agreed economic benefits but modified the computation.
Concurring with the ruling were Associate Justices Alfredo Benjamin Caguioa, Samuel Gaerlan and Jhosep Lopez.
Records of the case showed the labor dispute arose from a 2009 agreement renewing the five-year CBA between GNC and its labor unions, Guagua National Colleges Faculty Labor Union and Non-Teaching and Maintenance Labor Union.
It said that although GNC agreed to provide its workers with benefits such as rice subsidy, loyalty pay, and a clothing allowance, it delayed signing the draft CBA.
The labor union filed a notice of strike, accusing GNC of serious violations of the CBA.
THE Department of Labor and Employment intervened in the dispute by referring it to the NLRC for arbitration.
The NLRC later ruled in favor of the employees, as it held that GNC bargained in bad faith, which is considered an unfair labor practice.
It also declared the final draft CBA as the agreement between the GNC and its employees.
The NLRC likewise ordered GNC to pay its employees the agreed benefits covering the years 2009 to 2017.
The Court of Appeals affirmed the NLRC ruling, prompting GNC to bring the case to the High Court.
In its ruling upholding the CA decision, the SC explained that the power to enforce the terms of the CBA, including the redress of perceived violations does not reside exclusively with the voluntary arbitrators, adding that even the Labor Code itself recognizes that the NLRC may exercise jurisdiction when it involves gross violations of the CBAs as to amount to unfair labor practice.
“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,” it added.
However, the SC clarified that the NLRC acted more than jurisdiction on two fronts, adding that it could not enforce the signing bonus against GNC since it is a grant motivated by the goodwill generated when a CBA is successfully negotiated and signed between the employer and the union but that in the instant case no CBA was successfully negotiated by the parties and second when it erred in its computation as it awarded the “unimplemented CBA benefits since June 2009 up to the present time,” which is 2017.
The SC stressed that the NLRC should confine its computation of benefits up to May 31, 2014 only.
“Any dispute as to the economic benefits awardable after said date, including the covered employees thereof, should undergo the usual grievance machinery and referral to voluntary arbitration as contained in the parties’ CBA,” the SC added.
