Guagua National Colleges vs. Guagua National Colleges Faculty Labor Union

The NLRC possesses incidental jurisdiction to enforce the economic provisions of a CBA it imposed in a certified compulsory arbitration case arising from unfair labor practice, provided that the execution conforms to the terms and period of the final and executory decision being enforced; the NLRC may not award a signing bonus absent successful negotiation, nor may it compute benefits beyond the CBA's stipulated term without altering a final judgment.

Guagua National Colleges (GNC) is an educational institution in Sta. Filomena, Guagua, Pampanga. The Guagua National Colleges Faculty Labor Union (GNCFLU) and the Guagua National Colleges Non-Teaching and Maintenance Labor Union (GNCNTMLU), collectively the unions, serve as the bargaining agents for the school's teaching and non-teaching personnel. Between 1994 and 2009, the parties entered into three collective bargaining agreements (CBAs) covering both unions, with the very first CBA containing a "no-strike, no lock-out" clause deemed carried over in all subsequent CBAs.

On April 3, 2009, the unions signified their intent to negotiate the renewal of the CBA then in effect, which was set to expire on May 31, 2009. They attached their proposal to a letter received by GNC on the same day. Rather than submitting a reply or counterproposal, GNC called for a meeting on May 15, 2009. No agreement was reached, and the parties agreed to set another meeting. What the unions received next, however, was not a notice for the next meeting but a letter dated May 27, 2009 from GNC stating that management was not inclined to grant the monetary proposals submitted by the unions. Despite this, the unions requested another meeting, which was set on June 11, 2009. GNC's representatives were non-committal, but the unions reckoned that meeting as the start of the negotiation proper.

Thereafter, the parties engaged in several meetings. On August 24, 2009, GNC's representative confirmed the benefits to be included in the new CBA — loyalty pay, cash gift, rice subsidy, birthday gift, and clothing allowance — but did not accede to the unions' demand for an increased signing bonus. On October 9, 2009, the same representative signified that the signing of the benefits agreed upon might occur in the following meeting. Despite this, no signing took place and the parties failed to reach an agreement in succeeding meetings. The unions then filed a preventive mediation case before the National Conciliation and Mediation Board (NCMB). During mediation, the parties purportedly agreed to compose the final draft of the 2009-2014 CBA and settled to sign it on May 28, 2010 before the NCMB. On that date, however, counsel for GNC appeared instead and asked for 10 days to afford GNC the opportunity to submit a counterproposal. On the next scheduled meeting, no one appeared on behalf of GNC.

Fed up, the unions filed a notice of strike, charging GNC with bad faith bargaining, violation of its duty to bargain, gross violations of the CBA, and gross and blatant diminution of benefits, given that GNC supposedly stopped granting certain benefits to its employees. The strike was averted after the Secretary of Labor and Employment assumed jurisdiction over the case and certified it to the NLRC for compulsory arbitration, docketed as LCC No. 07-000005-10. The NLRC rendered its Decision dated March 31, 2011, finding GNC to have committed unfair labor practice by not bargaining in good faith, declaring the final draft of the CBA as the actual CBA between the parties effective June 1, 2009 to May 31, 2014, with the benefits agreed upon as of August 24, 2009 to be given retroactive effect as of June 1, 2009. The entry of judgment was recorded on June 22, 2011.

GNC challenged the NLRC ruling to the Supreme Court in G.R. No. 204693, resolved on July 13, 2016. The Court affirmed the NLRC, holding that GNC engaged in bad faith bargaining based on the collective acts of GNC, including the minutes of the October 9, 2009 meeting reflecting that GNC had already agreed to the benefits and that all that remained was to discuss them with the GNC President before signing, and the minutes of the conciliation proceedings before the NCMB revealing that the parties agreed to come up with a "final draft," which GNC later denied. The Court found that GNC's failure to follow through and its belated raising of financial incapacity to delay execution of the CBA were anathema to good faith bargaining. The July 13, 2016 Decision became final and executory on October 18, 2016.

Following receipt of the notice of entry of judgment, the unions moved to execute the NLRC judgment on March 22, 2017. The NLRC directed the immediate issuance of a writ of execution to collect from GNC the monetary award of PHP 4,676,288.32, covering unimplemented economic benefits under the CBA — rice subsidy, longevity pay, emergency relief allowance, and signing bonus. GNC's motion for reconsideration was denied. GNC then sought recourse before the CA, which partly granted the petition by excluding the signing bonus but maintaining the award for rice subsidy, longevity pay, and emergency relief allowance. Both parties moved for partial reconsideration; the CA issued an Amended Decision maintaining the modified award but clarifying that the unions were not required to reimburse any amount received as signing bonus. GNC then filed the present petition.

• No Monetary Award in Fallo: GNC argued that the NLRC gravely abused its discretion in issuing the writ of execution because neither the March 31, 2011 NLRC Decision in LCC Case No. 07-000005-10 nor the July 13, 2016 Supreme Court Decision in G.R. No. 204693 contained a monetary award in their fallo, such that granting one through execution would effectively alter an otherwise final and executory judgment.
• Voluntary Arbitration Required: GNC maintained that the enforcement of the parties' rights under the CBA is an economic issue that should have undergone voluntary arbitration rather than execution by the NLRC.
• Sleeping on Rights: GNC charged the unions with sleeping on their rights, since LCC No. 07-000005-10 had already become final and executory on June 22, 2011, but the unions did nothing to enforce it until six years later.
• Contradiction of Prior Ruling: GNC contended that the writ of execution contradicts the Court's categorical pronouncement in G.R. No. 204693 that the unions' "charge of unilateral withdrawal of benefits against GNC [is] without basis."

• NLRC Incidental Jurisdiction: Whether the NLRC has jurisdiction to enforce the economic provisions of a CBA through a writ of execution when the decision being executed did not contain an express monetary award in its fallo.
• Signing Bonus: Whether a signing bonus may be awarded as part of the execution of an imposed CBA.
• Period of Computation: Whether the NLRC erred in computing the unimplemented CBA benefits beyond May 31, 2014.
• Unilateral Withdrawal: Whether the writ of execution contradicts the Court's ruling in G.R. No. 204693 that the charge of unilateral withdrawal of benefits was without basis.
• Sleeping on Rights: Whether the unions slept on their rights by waiting six years to move for execution.

• NLRC Incidental Jurisdiction: Yes. The NLRC possesses incidental jurisdiction to enforce the provisions of a CBA it imposed in a certified compulsory arbitration case arising from unfair labor practice, even absent an express monetary award in the fallo, because the power to enforce a judgment includes the authority to give effect to its mandates.
• Signing Bonus: No. A signing bonus cannot be awarded where no CBA was successfully negotiated, as it is a grant motivated by goodwill generated when a CBA is voluntarily concluded between the parties.
• Period of Computation: No. The NLRC erred in computing benefits beyond May 31, 2014, because doing so altered the terms of its own final and executory decision, which implemented a CBA intended to govern only from June 1, 2009 to May 31, 2014.
• Unilateral Withdrawal: No. GNC misconstrued the Court's ruling; the finding that the charge of unilateral withdrawal was without basis during a specific period (2009-2011) did not mean GNC had paid the increased benefits for the entire CBA period.
• Sleeping on Rights: No. The unions cannot be faulted for awaiting the finality of the Court's Decision in G.R. No. 204693 before moving for execution, as this exercise of caution and respect for the Court's processes should not work to their prejudice.

• NLRC Incidental Jurisdiction: The jurisdiction of the NLRC under Article 224 of the Labor Code includes unfair labor practice cases and cases involving violations of the duty to bargain collectively under Article 264, as well as labor disputes certified by the Secretary of Labor and Employment for compulsory arbitration under Article 278. While Article 224(c) generally refers cases arising from the interpretation or implementation of a CBA to the grievance machinery and voluntary arbitration, Article 274 [261] recognizes that gross violations of a CBA — defined as flagrant and/or malicious refusal to comply with the economic provisions — may still be treated as unfair labor practice. Furthermore, a grant of jurisdiction implies the necessary and usual incidental powers essential to effectuate it, including the power to enforce judgments and mandates. Since LCC Case No. 07-000005-10 was a compulsory arbitration case arising from the breakdown of CBA negotiations that would have resulted in a strike, and since the NLRC had already assessed the terms of the CBA in finding GNC guilty of bad faith bargaining, the NLRC was in the best position to enforce the same. Requiring the parties to engage the grievance machinery and submit to a voluntary arbitrator would only promote multiplicity of suits and further prolong the settlement of rights and obligations. The NLRC's power to execute its rulings is not a blind ministerial act but carries with it the right to look into the correctness of the execution and to consider supervening events.

• Signing Bonus: A signing bonus is a grant motivated by the goodwill generated when a CBA is successfully negotiated and signed between the employer and the union. In this case, no CBA was successfully negotiated by the parties; the CBA was imposed by the NLRC after GNC was found to have bargained in bad faith. Because the negotiations were unsuccessful and the CBA was imposed rather than voluntarily concluded, no signing bonus can be awarded, notwithstanding that a potential signing bonus is part and parcel of the CBA's terms. The CA correctly excluded the signing bonus from the monetary award.

• Period of Computation: The March 31, 2011 NLRC Decision implemented a CBA intended to govern the relationship of the parties between June 1, 2009 and May 31, 2014. The NLRC accepted the unions' computation of unimplemented CBA benefits reckoned from June 1, 2009 "up to the present date," which at the time was 2017. By applying the CBA's provisions beyond May 31, 2014, the NLRC inadvertently altered the terms of its own final and executory decision. While the NLRC has incidental jurisdiction to give effect to its rulings and may consider supervening events, it cannot alter the metes and bounds of a final and executory decision. The doctrine of immutability of judgment applies to the NLRC and is based on sound public policy; none of the recognized exceptions are applicable here. Following General Milling Corporation-Independent Labor Union (GMC-ILU) vs. General Milling Corporation, the computation of benefits under the imposed CBA should be limited to the CBA's stated term. Any dispute as to economic benefits awardable after May 31, 2014 should undergo the usual grievance machinery and referral to voluntary arbitration as provided in the parties' CBA.

• Unilateral Withdrawal: GNC misconstrued the Court's ruling in G.R. No. 204693. The charge of unilateral withdrawal was supposedly committed during a specific period between 2009 and 2011. The unions' failure to prove withdrawal of benefits during that period does not mean GNC was able to pay the increased benefits for the entire effectivity period of June 1, 2009 to May 31, 2014. The Court in G.R. No. 204693 expressly stated that while the charge of unilateral withdrawal was without basis, "this does not have any effect and therefore does not change the finding that GNC committed a violation of its duty to bargain."

• Sleeping on Rights: The unions may not be faulted for awaiting the finality of the Court's Decision in G.R. No. 204693 before moving to execute the NLRC's ruling. This exercise of caution and respect for the Court's processes shall not work to their prejudice.

• Incidental Jurisdiction — A grant of jurisdiction to a tribunal, barring prohibitive legislation, implies the necessary and usual incidental powers essential to effectuate it, including the power and authority to do all things reasonably necessary for the administration of justice within the scope of its jurisdiction and for the enforcement of its judgments and mandates. The Court applied this doctrine to hold that the NLRC, having been conferred jurisdiction over the compulsory arbitration case arising from unfair labor practice and having assessed the CBA's terms in rendering its decision, possessed incidental jurisdiction to enforce the CBA's economic provisions through a writ of execution.

• Immutability of Judgment — A final and executory judgment may no longer be altered or modified, even by the court that rendered it, based on sound public policy. The Court applied this doctrine to the NLRC, holding that while the NLRC has incidental jurisdiction to execute its rulings and may consider supervening events, it cannot alter the metes and bounds of a final and executory decision. Computing CBA benefits beyond the CBA's stated term (May 31, 2014) constituted an impermissible alteration of the NLRC's own final decision.

• Signing Bonus as Goodwill — A signing bonus is a grant motivated by the goodwill generated when a CBA is successfully negotiated and signed between the employer and the union. Where no CBA was successfully negotiated and the CBA was instead imposed by the labor tribunal, no signing bonus may be awarded because the essential precondition — goodwill from voluntary agreement — is absent.

• Gross Violations of CBA as Unfair Labor Practice — Under Article 274 [261] of the Labor Code, violations of a CBA, except those which are gross in character, shall no longer be treated as unfair labor practice and shall be resolved as grievances under the CBA. Gross violations of a CBA are defined as flagrant and/or malicious refusal to comply with the economic provisions of such agreement. The Court relied on this provision to clarify that the power to enforce the terms of a CBA, including the redress of perceived violations, does not reside exclusively with voluntary arbitrators; the NLRC may exercise jurisdiction when CBA violations are gross in character and amount to unfair labor practice.

• "The power to enforce the terms of the CBA, including the redress of perceived violations thereof, does not reside exclusively with the voluntary arbitrators. The Labor Code itself recognizes that the NLRC may exercise jurisdiction when it involves gross violations of CBAs as to amount to unfair labor practice." — This passage articulates the doctrinal basis for the NLRC's concurrent authority over gross CBA violations, distinguishing such cases from ordinary grievances reserved for voluntary arbitration.

• "To adopt the stance of GNC that the parties should engage the grievance machinery and submit the case before a voluntary arbitrator to implement the terms of the CBA would only promote multiplicity of suits and further prolong the settlement of rights and obligations between the parties." — This statement provides the practical rationale for recognizing the NLRC's incidental jurisdiction in the specific context of an imposed CBA following a soured labor relationship.

• "In applying the provisions of this CBA beyond the period of May 31, 2014, the NLRC inadvertently altered the terms of its own final and executory decision." — This passage identifies the critical error in the NLRC's execution: extending the imposed CBA's economic benefits beyond its stipulated term, thereby violating the immutability doctrine.

• "A signing bonus is a grant motivated by the goodwill generated when a CBA is successfully negotiated and signed between the employer and the union. In the instant case, no CBA was successfully negotiated by the parties." — This defines the nature of a signing bonus and explains why it cannot be awarded when a CBA is imposed rather than voluntarily concluded.

• Guagua National Colleges vs. Guagua National Colleges Faculty Labor Union, 790 Phil. 106 (2016) — The prior Supreme Court decision in G.R. No. 204693, which affirmed the NLRC's finding that GNC committed bad faith bargaining and declared the final draft CBA as the parties' actual CBA for June 1, 2009 to May 31, 2014. The Court relied on this as the judgment whose execution was at issue and clarified that its pronouncement on the lack of basis for the unilateral withdrawal charge did not negate the finding of violation of the duty to bargain.

• General Milling Corporation-Independent Labor Union (GMC-ILU) vs. General Milling Corporation, 667 Phil. 371 (2011) — Controlling precedent followed by the Court. The Court cited this case for the proposition that an order of execution which varies the tenor of the judgment or exceeds the terms thereof is a nullity, and that computation of benefits under an imposed CBA should be limited to the CBA's stated term, with any benefits beyond that period to be threshed out through the grievance machinery and voluntary arbitration.

• University of the Immaculate Conception vs. Office of the Secretary of Labor and Employment, 769 Phil. 630 (2015) — Cited for the doctrine of incidental jurisdiction, specifically that a grant of jurisdiction implies the necessary and usual incidental powers essential to effectuate it, including the power to enforce judgments and mandates.

• Sampaguita Garments Corp. vs. NLRC, 303 Phil. 276 (1994) — Cited for the principle that the NLRC's power to execute its rulings is not a blind ministerial act but carries with it the right to look into the correctness of the execution and to consider supervening events.

• University of Sto. Tomas vs. Samahang Manggagawa ng UST (SM-UST), 616 Phil. 474 (2009) — Cited for the definition of a signing bonus as a grant motivated by goodwill generated when a CBA is successfully negotiated and signed.

• Toledo Construction Corp. Employees' Association-ADLO-KMU vs. Toledo Construction Corp., 932 Phil. 239 (2022) — Cited for the doctrine of immutability of judgment as applied to the NLRC and the recognized exceptions thereto.

• Article 224, Labor Code (renumbered 2015) — Defines the jurisdiction of Labor Arbiters and the Commission, including unfair labor practice cases and cases arising from violations of Article 264. The Court relied on this provision to establish the NLRC's jurisdiction over the underlying compulsory arbitration case. Article 224(c) was also cited for the general rule that cases arising from the interpretation or implementation of CBAs shall be referred to the grievance machinery and voluntary arbitration.

• Article 264, Labor Code (renumbered 2015) — Governs strikes, picketing, and lockouts, including the Secretary of Labor's authority to assume jurisdiction over labor disputes in industries indispensable to the national interest and certify them to the Commission for compulsory arbitration. The Court cited this as the basis for the NLRC's cognizance of the certified case.

• Article 274 [261], Labor Code (renumbered 2015) — Defines the jurisdiction of voluntary arbitrators and provides that violations of a CBA, except those which are gross in character, shall no longer be treated as unfair labor practice. Gross violations are defined as flagrant and/or malicious refusal to comply with the economic provisions of the CBA. The Court relied on this provision to establish that the NLRC may exercise jurisdiction over gross CBA violations amounting to unfair labor practice, and that the power to enforce CBA terms does not reside exclusively with voluntary arbitrators.

• Article 278, Labor Code (renumbered 2015) — Governs strikes, picketing, and lockouts, including the Secretary of Labor's power to assume jurisdiction and certify disputes for compulsory arbitration. Cited as the statutory basis for the certification of the case to the NLRC.

• Article 253-A, Labor Code — Referenced in the NLRC's original decision regarding the parties' freedom to renegotiate the economic provisions of the CBA not later than May 31, 2012.

Caguioa (Chairperson), Gaerlan, and J. Lopez concurred. Singh was on leave.