Primary Holding
A collective bargaining agreement’s clear terms granting academic teaching personnel a grant-in-aid equivalent to salary and allowance for scholarship study must be applied as written, and any doubt or ambiguity in the CBA must be resolved in favor of labor.
Background
Holy Cross of Davao College, Inc. is a tertiary level educational institution at Sta. Ana Avenue, Davao City, while Holy Cross of Davao Faculty Union - KAMAPI is the sole and exclusive bargaining representative of its permanent academic teaching personnel. In June 1997, the parties executed a collective bargaining agreement providing for a faculty development scholarship for academic teaching personnel. The Japanese Government, through the Japan Information and Cultural Center, offered the 1999 Monbusho scholarship grant (In-Service Training for Teachers), and petitioner issued a policy statement and guidelines on educational trips abroad for school year 1998 to 1999. Article 1702 of the Civil Code supplies the statutory backdrop for construing labor contracts in favor of labor.
History
2001 – 2005-
Mar 26, 2001
Voluntary Arbitrator
Rendered a Decision ordering petitioner to pay Jean A. Legaspi her grant-in-aid benefits, declaring non-implementation of Article XIII, Section 1 of the CBA, and directing petitioner to cease and desist from a similar offense.
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2 mos 25 days later
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Jun 20, 2001
Voluntary Arbitrator
Denied petitioner’s motion for reconsideration in a Resolution.
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Court of Appeals
Petitioner filed a petition for review under Rule 43 of the 1997 Rules of Civil Procedure, as amended.
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Jun 5, 2002
Court of Appeals
Promulgated its Decision affirming the Voluntary Arbitrator’s assailed Decision in CA-G.R. SP No. 65507.
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4 mos 13 days later
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Oct 18, 2002
Court of Appeals
Issued a Resolution denying petitioner’s motion for reconsideration.
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Supreme Court
Petitioner filed a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended.
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Jun 27, 2005
Supreme Court
Denied the petition, affirmed the Court of Appeals’ Decision dated June 5, 2002 and Resolution dated October 18, 2002 in CA-G.R. SP No. 65507, and ordered costs against petitioner.
Facts
Holy Cross of Davao College, Inc. is a tertiary level educational institution at Sta. Ana Avenue, Davao City. In June 1997, it executed a collective bargaining agreement with Holy Cross of Davao Faculty Union - KAMAPI, the sole and exclusive bargaining representative of all permanent academic teaching personnel of the college, elementary, high school, and college teaching force. The CBA provided for a faculty development scholarship for academic teaching personnel. Section 1, Article XIII of the CBA stated that management shall grant all academic personnel a grant-in-aid program, where academic teaching personnel, whenever scholarship opportunities arise, are afforded a leave of absence to further their studies in institutions of higher learning with a grant-in-aid equivalent to their salary and allowance, subject to conditions, including that the grantee serve the school for at least two years for every year of scholarship study.
On January 16, 1998, petitioner received a letter of invitation for the 1999 Monbusho scholarship grant (In-Service Training for Teachers) offered and sponsored by the Japanese Government through the Japan Information and Cultural Center (JICC). Jean Legaspi, a permanent English teacher in petitioner’s high school department, submitted her application. On March 31, 1999, petitioner issued a policy statement and guidelines on educational trips abroad for school year 1998 to 1999. In a letter dated August 25, 1999, JICC informed Legaspi that she was selected as a recipient of the scholarship. She then requested petitioner to allow her to be on study leave with grant-in-aid equivalent to her 18 months salary and allowance, pursuant to Section 1, Article XIII of the CBA. Petitioner denied her request, claiming that she was not entitled to grant-in-aid under its Policy Statement and Guidelines for Trips Abroad for Professional Growth. Nevertheless, petitioner granted her 12 months study leave without pay from October 1999 to September 2000.
Before she left for Japan, Legaspi asked respondent union KAMAPI to submit to the Grievance Committee petitioner’s refusal to grant her claim for grant-in-aid, but the matter was not settled. Respondent then filed with the National Conciliation and Mediation Board (NCMB), Regional Office No. XI, Davao City, a complaint for payment of grant-in-aid against petitioner. In a Submission Agreement dated June 23, 2000, the parties stipulated to submit the case for voluntary arbitration.
The Voluntary Arbitrator and the Court of Appeals found that Legaspi satisfied the CBA requirements. The Court of Appeals found that her foreign training was related to her work and would advance her qualifications; that the fact that the medium of instruction was Japanese did not negate the program’s relevance to her work as an English teacher; and that although only a certificate would be conferred, the CBA’s reference to “higher studies” did not limit the benefit to programs granting degrees.
Arguments of the Petitioners
- Academic Freedom: Petitioner contended that the Court of Appeals erred in interpreting the parties’ CBA, thereby restricting petitioner’s exercise of academic freedom.
- Non-Compliance with CBA Requirements: Petitioner maintained that it is not obliged to grant Jean Legaspi a grant-in-aid because she failed to comply with the substantive requirements set forth in their CBA, such as (1) that the course is within her area of competence and (2) that she will acquire a higher academic degree.
- Monbusho Scholarship: Petitioner argued that the Monbusho scholarship is a non-degree program outside her area of competence (English).
- Policy Statement and Guidelines: Petitioner claimed that Legaspi was not entitled to grant-in-aid under its Policy Statement and Guidelines for Trips Abroad for Professional Growth.
Issues
- Entitlement to Grant-in-Aid: Whether Jean Legaspi is entitled to grant-in-aid benefits in light of the CBA between the parties.
Ruling
- Entitlement to Grant-in-Aid: Yes. Jean Legaspi is entitled to grant-in-aid benefits under Section 1, Article XIII of the CBA. The CBA is the law between the parties, its clear terms must be applied, and any doubt or ambiguity must be resolved in favor of labor under Article 1702 of the Civil Code.
Ruling Rationale
- Entitlement to Grant-in-Aid: The CBA’s Section 1, Article XIII provides that management shall grant all academic personnel a grant-in-aid program, where academic teaching personnel, whenever scholarship opportunities arise, are afforded a leave of absence to further their studies in institutions of higher learning with a grant-in-aid equivalent to their salary and allowance, under stated conditions. The policy statement’s paragraph 2 likewise provides that the school may provide financial assistance and that the employee is the official representative of the school upon recommendation of the office head, receiving regular salary. These provisions are clear: academic teaching personnel like Legaspi, as recipient of a scholarship grant, are entitled to a leave of absence with a grant-in-aid equivalent to their monthly salary and allowance, provided the grant promotes professional growth or enhances studies in institutions of higher learning. Because the provisions are clear, they need no interpretation; contracts not ambiguous are interpreted according to their literal meaning and not beyond their obvious intendment. Any doubt or ambiguity in the CBA between management and union members must be resolved in favor of the latter under Article 1702 of the Civil Code. The CBA is the law between the parties; those entitled to its benefits can invoke its provisions, and if an obligation is not fulfilled, the aggrieved party may go to court for redress. The Court of Appeals did not err in affirming the Voluntary Arbitrator’s decision. The appellate court’s findings that Legaspi satisfied the CBA requirements, that her foreign training was related to her work and would advance her qualifications, and that the CBA’s reference to “higher studies” did not limit the benefit to degree-granting programs were affirmed. Petitioner’s contentions lack merit.
Doctrines
- CBA as law between the parties — Terms and conditions of a collective bargaining contract constitute the law between the parties. Those entitled to its benefits can invoke its provisions; if an obligation therein imposed is not fulfilled, the aggrieved party has the right to go to court for redress. Applied: Legaspi, as a CBA-covered academic teaching personnel and scholarship recipient, could invoke Section 1, Article XIII to claim grant-in-aid; the union could seek redress when petitioner refused.
- Liberal construction of labor contracts in favor of labor — Under Article 1702 of the Civil Code, in case of doubt, all labor legislation and all labor contracts shall be construed in favor of the safety and decent living for the laborer. Applied: Any doubt or ambiguity in the CBA between management and union members must be resolved in favor of the latter; thus, ambiguities as to whether the Monbusho training was “higher studies” or relevant to Legaspi’s work were resolved in her favor.
- Clear contracts interpreted literally — Contracts which are not ambiguous are to be interpreted according to their literal meaning and not beyond their obvious intendment. Applied: The CBA and policy statement clearly entitled academic teaching personnel receiving scholarship grants to leave with grant-in-aid equivalent to salary and allowance; no further interpretation was needed.
- CBA prevails over unilateral policy statements — Unilaterally imposed orders or rules qualifying the terms of a CBA are subordinate to the CBA; at most, such rules are suppletory and can neither contradict nor undermine the CBA. Applied: Petitioner’s Policy Statement and Guidelines on trips abroad could not defeat Legaspi’s CBA grant-in-aid entitlement.
Key Excerpts
- "To begin with, any doubt or ambiguity in the contract (CBA) between management and the union members should be resolved in favor of the latter. This is pursuant to Article 1702 of the Civil Code which provides: "(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."" — This states the Supreme Court’s controlling principle for construing the CBA and supplies the basis for resolving ambiguities in favor of the union member.
- "The above provisions state that academic teaching personnel, like Jean Legaspi, as recipient of a scholarship grant are entitled to a leave of absence with a grant-in-aid equivalent to their monthly salary and allowance, provided such grant is to promote their professional growth or to enhance their studies in institutions of higher learning. Such provisions need no interpretation for they are clear. Contracts which are not ambiguous are to be interpreted according to their literal meaning and not beyond their obvious intendment." — This is the ratio decidendi on entitlement: the CBA and policy statement clearly grant the benefit to a scholarship recipient like Legaspi.
- "In Mactan Workers Union vs. Aboitiz, we held 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. In the event that an obligation therein imposed is not fulfilled, the aggrieved party has the right to go to court for redress."" — This is the canonical formulation of the CBA-as-law doctrine applied by the Court to affirm the union’s right to seek redress.
- "Since the collective bargaining agreement is considered the law between the parties, containing as it does the agreed terms of employment of the employee with his employer, unilaterally imposed orders or rules qualifying the terms contained in the agreement are subordinate to the CBA. At most, such rules, such as the rules on trips abroad formulated by petitioner a few months before Legaspi’s application, are merely suppletory and can neither contradict nor undermine the terms found in the CBA." — This passage, quoted from the Court of Appeals in the Supreme Court’s decision, explains why petitioner’s later policy statement could not override the CBA’s grant-in-aid provision.
Precedents Cited
- Mactan Workers Union vs. Aboitiz, G.R. No. L-30241, June 30, 1972, 45 SCRA 577, 581 — cited by the Supreme Court for the rule that the terms and conditions of a CBA constitute the law between the parties; those entitled to its benefits can invoke its provisions, and the aggrieved party may go to court for redress if an obligation is not fulfilled. This was the controlling precedent applied to affirm Legaspi’s entitlement.
- Herrera vs. Petrophil Corp., 146 SCRA 385 (1986) — cited in the decision for the rule that contracts which are not ambiguous are to be interpreted according to their literal meaning and not beyond their obvious intendment. The Court used this to hold that the CBA and policy statement clearly entitled Legaspi to the grant-in-aid.
- Plastic Town Center Corporation vs. NLRC, G.R. No. 81176, April 19, 1989, 172 SCRA 580, 587 — cited in footnote for Article 1702 of the Civil Code, the rule that in case of doubt, labor legislation and labor contracts are construed in favor of the safety and decent living for the laborer. The Court relied on this principle in resolving doubts in favor of the union member.
Provisions
- Article 1702, Civil Code — Provides: "(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." Applied: any doubt or ambiguity in the CBA between management and union members was resolved in favor of the union member, Legaspi.
- Section 1, Article XIII, Collective Bargaining Agreement — Faculty Development provision: management shall grant all academic personnel a grant-in-aid program, where academic teaching personnel, whenever scholarship opportunities arise, are afforded a leave of absence to further their studies in institutions of higher learning with a grant-in-aid equivalent to their salary and allowance, subject to conditions. Applied: Legaspi, as a recipient of a scholarship grant, was entitled to the grant-in-aid.
- Paragraph 2, Policy Statement and Guidelines for Trips Abroad for Professional Growth (SY 1998-1999) — Provides that the school may provide financial assistance and that the employee is the official representative of the school upon recommendation of the office head, receiving regular salary. Applied: The Court read it with the CBA as supporting the grant-in-aid entitlement; it could not contradict the CBA.
- Rule 45, 1997 Rules of Civil Procedure, as amended — The petition for review on certiorari was filed under this Rule. Applied: The Supreme Court reviewed the Court of Appeals’ Decision and Resolution.
- Rule 43, 1997 Rules of Civil Procedure, as amended — Petitioner filed with the Court of Appeals a petition for review under this Rule. Applied: The Court of Appeals exercised appellate review over the Voluntary Arbitrator’s Decision.
Notable Concurring Opinions
Justice Panganiban (Chairman), Justice Corona, Justice Carpio-Morales, and Justice Garcia concurred.