In Holy Cross of Davao College, Inc. vs. Holy Cross of Davao Faculty Union – KAMAPI, the Supreme Court affirmed that ambiguities in collective bargaining agreements (CBAs) must be resolved in favor of labor. This ruling underscores the importance of upholding the rights and benefits granted to employees under CBAs, ensuring that educational institutions fulfill their commitments to faculty development and scholarship programs. The decision highlights that CBA provisions should be interpreted according to their literal meaning, and any doubts should be construed to promote the welfare of the working class. This case reinforces the principle that CBAs serve as the law between the parties, and employees are entitled to invoke their provisions for redress.

Educational Growth vs. Institutional Policy: Who Prevails in CBA Interpretation?

The case arose when Jean Legaspi, a permanent English teacher at Holy Cross of Davao College, was selected for the Monbusho scholarship grant, a program sponsored by the Japanese Government. Legaspi requested a study leave with grant-in-aid, as provided under the Collective Bargaining Agreement (CBA) between Holy Cross of Davao College and the Holy Cross of Davao Faculty Union – KAMAPI. However, the college denied her request, citing its “Policy Statement and Guidelines for Trips Abroad for Professional Growth,” which did not entitle her to the grant-in-aid. Despite the denial, the college granted her a 12-month study leave without pay. This led the faculty union to file a complaint with the National Conciliation and Mediation Board (NCMB), eventually resulting in voluntary arbitration.

The Voluntary Arbitrator ruled in favor of Legaspi, ordering the college to pay her the grant-in-aid benefits. The college filed a motion for reconsideration, which was denied. Subsequently, the college appealed to the Court of Appeals, which affirmed the arbitrator’s decision. The Court of Appeals emphasized that the terms of the CBA were clear and that Legaspi had met all the requirements under the agreement. It held that unilaterally imposed rules or orders by the college could not undermine the terms of the CBA, which is considered the law between the parties. This decision prompted the college to elevate the matter to the Supreme Court, questioning the interpretation of the CBA and its obligation to provide the grant-in-aid.

The Supreme Court addressed whether Jean Legaspi was entitled to the grant-in-aid benefits based on the existing CBA. The court anchored its decision on Article 1702 of the Civil Code, stating:

“(I)n case of doubt, all labor legislation and all labor contracts shall be construed in favor of the safety and decent living for the laborer.”

Building on this principle, the Court examined Section 1, Article XIII of the CBA, which outlines the faculty development program:

“Section 1. FACULTY DEVELOPMENT. It has always been the policy of the Holy Cross of Davao College that academic teaching personnel must develop within their areas of competence and in so doing have exercised its prerogative to demand that academic teaching personnel take the necessary measure to effect their upgrading in acquiring higher academic degree… the Management shall grant to all academic personnel a grant-in-aid program… under the following conditions…”

The CBA provision stipulates that academic teaching personnel, who receive scholarship grants to promote professional growth or enhance studies in higher learning institutions, are entitled to a leave of absence with a grant-in-aid. This benefit is equivalent to their monthly salary and allowance. The Supreme Court found that the CBA’s provisions were clear and needed no further interpretation. The Court reiterated the principle that contracts, which are not ambiguous, must be interpreted according to their literal meaning. This reinforces the binding nature of the CBA and its importance in defining the rights and obligations of both the employer and the employees.

In analyzing the college’s policy statement and guidelines, the Court noted the inconsistency with the CBA. The guidelines stated that employees who are official representatives of the school may receive their regular salary. However, this condition was not explicitly stated in the CBA as a prerequisite for the grant-in-aid. The Court emphasized that the CBA, as the primary agreement between the parties, should prevail over unilaterally imposed policies. This approach contrasts with the college’s attempt to impose additional conditions not found in the CBA, highlighting the importance of adhering to the agreed-upon terms in collective bargaining.

The Supreme Court cited Mactan Workers Union vs. Aboitiz to reinforce the significance of CBAs, stating that “the terms and conditions of a collective bargaining contract constitute the law between the parties. Those who are entitled to its benefits can invoke its provisions.” The Court further explained that if an obligation imposed by the CBA is not fulfilled, the aggrieved party has the right to seek legal redress. This underscores the enforceability of CBAs and the legal protection afforded to employees who rely on their provisions. The college’s failure to provide the grant-in-aid to Jean Legaspi, despite her fulfilling the requirements outlined in the CBA, constituted a violation of her rights under the agreement.

The Court emphasized that any ambiguity in the CBA should be construed in favor of the employees, aligning with Article 1702 of the Civil Code. This principle is rooted in the recognition of the unequal bargaining power between employers and employees. It aims to protect the rights and welfare of the working class by ensuring that labor contracts are interpreted to promote their safety and decent living. The college’s attempt to narrowly interpret the CBA to exclude Legaspi from receiving the grant-in-aid was contrary to this principle and was therefore rejected by the Court. This underscores the Court’s commitment to upholding the rights of employees and ensuring fair labor practices.

In conclusion, the Supreme Court found no error in the Court of Appeals’ decision and resolution, thereby affirming the order for Holy Cross of Davao College to pay Jean Legaspi her grant-in-aid benefits. This decision serves as a reminder to employers to honor the terms of their CBAs and to interpret them in a manner that favors the welfare of their employees. The case reinforces the legal protection afforded to employees under collective bargaining agreements and highlights the importance of adhering to the principles of fair labor practices. It ensures that educational institutions fulfill their commitments to faculty development, thereby contributing to the improvement of education and the well-being of educators.

FAQs

What was the key issue in this case?	The key issue was whether Jean Legaspi, a faculty member, was entitled to a grant-in-aid benefit under the Collective Bargaining Agreement (CBA) for a scholarship she received.
What is a Collective Bargaining Agreement (CBA)?	A CBA is a negotiated agreement between an employer and a labor union that sets out the terms and conditions of employment for union members. It serves as a contract that defines the rights and responsibilities of both parties.
What does the Civil Code say about interpreting labor contracts?	Article 1702 of the Civil Code states that in case of doubt, all labor legislation and labor contracts shall be construed in favor of the safety and decent living for the laborer. This principle guides courts in resolving ambiguities in favor of employees.
What did the Court of Appeals rule in this case?	The Court of Appeals affirmed the Voluntary Arbitrator’s decision, holding that Jean Legaspi was entitled to the grant-in-aid benefit under the CBA. The court emphasized that the terms of the CBA were clear and binding on the parties.
Why did the Supreme Court deny the petition?	The Supreme Court denied the petition because it found no error in the Court of Appeals’ decision. The Court held that the CBA’s provisions were clear and should be interpreted in favor of the employee, Jean Legaspi.
What is the significance of the Mactan Workers Union vs. Aboitiz case?	The Mactan Workers Union case emphasizes that the terms and conditions of a collective bargaining contract constitute the law between the parties. It reinforces the principle that employees are entitled to invoke the provisions of the CBA for their benefit.
Can an employer’s internal policies override the terms of a CBA?	No, an employer’s unilaterally imposed policies cannot override the terms of a CBA. The CBA is considered the primary agreement between the parties, and any conflicting internal policies are subordinate to it.
What are the implications of this ruling for employers?	This ruling reminds employers to honor the terms of their CBAs and to interpret them in a manner that favors the welfare of their employees. It underscores the importance of adhering to fair labor practices and fulfilling commitments made in collective bargaining agreements.

This case reaffirms the judiciary’s commitment to protecting the rights of laborers and ensuring that collective bargaining agreements are upheld. By resolving ambiguities in favor of the employee, the Supreme Court promotes fairness and equity in labor relations. This decision serves as a valuable precedent for interpreting CBAs and safeguarding the interests of the working class.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Holy Cross of Davao College, Inc. vs. Holy Cross of Davao Faculty Union – KAMAPI, G.R. NO. 156098, June 27, 2005