Royal Plant Workers Union vs. Coca-Cola Bottlers Philippines, Inc.-Cebu Plant

The removal of chairs for bottling operators is a valid exercise of management prerogative when done in good faith to improve business efficiency and safety, especially when compensated by other measures like adjusted work schedules; the long-term provision of such chairs does not ripen into a vested right or a benefit protected under the non-diminution rule of Article 100 of the Labor Code, which applies to monetary benefits or privileges with monetary equivalents.

For over three decades, Coca-Cola Bottlers Philippines, Inc. (CCBPI) provided chairs for its bottling operators at its Cebu plant. In September 2008, pursuant to a national directive aligned with its "I Operate, I Maintain, I Clean" program, CCBPI removed these chairs. The company reasoned that the operators' tasks required constant movement and that removing the chairs would enhance efficiency and prevent operators from sleeping on the job, thereby reducing the risk of accidents. This unilateral decision by management prompted the Royal Plant Workers Union (ROPWU) to initiate a grievance, which eventually led to the legal dispute.

• Petitioner Royal Plant Workers Union (ROPWU) is the union for employees at respondent Coca-Cola Bottlers Philippines, Inc. (CCBPI) in its Cebu plant.
• Bottling operators in Bottling Line 2 had been provided with chairs since 1974, and those in Bottling Line 1 since 1988.
• In September 2008, CCBPI removed the chairs pursuant to a national directive related to its "I Operate, I Maintain, I Clean" program, which required operators to constantly move about.
• CCBPI justified the removal as a measure to increase efficiency and prevent operators, who work with moving machinery, from falling asleep and getting injured.
• Simultaneously, CCBPI changed the work-break schedule, reducing the work period from 2.5 hours to 1.5 hours before a 30-minute break, effectively increasing the frequency of rest periods.
• The dispute went through the CBA's grievance machinery and conciliation-mediation proceedings at the NCMB, but no settlement was reached.
• The parties submitted the issue of the validity of the chair removal to a Voluntary Arbitration Panel, which ruled in favor of the Union.

• The correct remedy to challenge a Voluntary Arbitrator's decision at the Court of Appeals is a petition for certiorari under Rule 65, not a petition for review under Rule 43.
• The removal of chairs, a practice existing for over 30 years, is a unilateral withdrawal of a benefit that has ripened into a vested right, violating the principle of non-diminution of benefits under Article 100 of the Labor Code.
• The action violates Occupational Health and Safety Standards and the State's policy to ensure just and humane working conditions.
• Management prerogative is not absolute and must be exercised within the limits of law, the CBA, and principles of fair play and justice.
• There was no evidence of poor performance or sleeping on the job that would justify the removal of the chairs.

• A petition for review under Rule 43 of the Rules of Court is the proper remedy to appeal the decision of the Voluntary Arbitration Panel to the Court of Appeals.
• The removal of the chairs is a valid and legitimate exercise of management prerogative, intended to optimize employee efficiency and ensure safety.
• The decision was made in good faith and was not intended to circumvent the rights of employees under the law or the CBA.
• The removal of the chairs was compensated by a more advantageous work-break schedule, with shorter work periods and more frequent breaks.
• The provision of chairs is not a benefit covered by Article 100 of the Labor Code, which pertains to monetary benefits or their equivalents.
• The CBA explicitly states that benefits not expressly provided for are purely voluntary acts of the company and do not establish a binding obligation.

• Procedural Issues:
  • Whether a petition for review under Rule 43 of the Rules of Court is the proper remedy to appeal a decision of a Voluntary Arbitrator to the Court of Appeals.
• Substantive Issues:
  • Whether the removal of the bottling operators' chairs was a valid exercise of management prerogative.
  • Whether the long-standing practice of providing chairs constituted a benefit protected from unilateral withdrawal by the non-diminution of benefits principle under Article 100 of the Labor Code.

• Procedural:
  • Yes, the Supreme Court affirmed that a petition for review under Rule 43 is the proper remedy to appeal a decision of a Voluntary Arbitrator to the Court of Appeals. The Court reiterated the well-settled doctrine that awards of voluntary arbitrators are treated like those of quasi-judicial agencies, making them appealable to the CA under Rule 43.
• Substantive:
  • Yes, the removal of the chairs was a valid exercise of management prerogative. The Court found that the decision was made in good faith, was part of a national program to increase work efficiency, and was not intended to harm workers. The action was further justified by the compensatory measure of reducing work periods and increasing break frequency, which was deemed a fair and just work schedule.
  • No, the provision of chairs is not a benefit covered by the non-diminution rule in Article 100 of the Labor Code. The Court clarified that the term "benefits" under this rule refers to monetary benefits or privileges with monetary equivalents that form part of the employees' wage or compensation. As the chairs do not fall under this category, their removal did not violate Article 100. Furthermore, the CBA itself stipulated that unlisted privileges were purely voluntary and did not create a binding obligation on the company.

• Management Prerogative — This refers to the inherent right of an employer to regulate, according to its own discretion and judgment, all aspects of employment. In this case, the Court held that CCBPI's removal of the chairs was a valid exercise of this prerogative, as it was a legitimate business decision aimed at improving efficiency and safety, was implemented in good faith, and was accompanied by compensatory adjustments to the employees' work schedule.
• Non-Diminution of Benefits (Article 100, Labor Code) — This principle dictates that an employer cannot eliminate or reduce supplements or other employee benefits being enjoyed at the time of the promulgation of the Labor Code. The Court ruled that this doctrine was inapplicable because the term "benefits" under Article 100 is limited to monetary benefits or privileges that have a monetary equivalent and form part of the employee's wage or salary. The provision of chairs, being a non-monetary item, was not covered by this protection.

• "Without a doubt, equating the provision of chairs to the bottling operators as something within the ambit of 'benefits' in the context of Article 100 of the Labor Code is unduly stretching the coverage of the law. The interpretations of Article 100 of the Labor Code do not show even with the slightest hint that such provision of chairs for the bottling operators may be sheltered under its mantle."

• Samahan Ng Mga Manggagawa Sa Hyatt (SAMASAH-NUWHRAIN) v. Hon. Voluntary Arbitrator Buenaventura C. Magsalin — Cited as the prevailing jurisprudence confirming that a decision of a voluntary arbitrator is appealable to the Court of Appeals via a petition for review under Rule 43.
• Luzon Development Bank v. Association of Luzon Development Bank Employees — Referenced as the landmark case that established the rule that decisions of voluntary arbitrators should be appealable to the Court of Appeals in line with the procedure for quasi-judicial agencies.
• Julie's Bakeshop v. Arnaiz — Cited to define the scope of management prerogative, while also emphasizing that its exercise is not absolute and must be done in good faith and with due regard to the rights of labor.
• Eastern Telecommunication Phils. Inc. v. Eastern Telecoms Employees Union — Used as an example, along with other cases, to illustrate that the non-diminution of benefits rule under Article 100 applies to monetary benefits like bonuses, holiday pay, and salary increases, thereby supporting the Court's restrictive interpretation of the rule.

• Rule 43, 1997 Rules of Civil Procedure — This rule was central to the procedural issue, with the Court affirming its application for appealing decisions of voluntary arbitrators to the Court of Appeals.
• Article 100, Labor Code (Prohibition against elimination or diminution of benefits) — Invoked by the petitioner union, but the Court ruled it was inapplicable because the provision of chairs is not a monetary benefit or a supplement with a monetary equivalent.
• Article 132, Labor Code (Facilities for Women) — Cited by the Court to highlight that while the law requires employers to provide seats for female employees, no similar requirement exists for male employees, who were the subjects of this case.
• Article 1, Section 2 of the Collective Bargaining Agreement (CBA) — This provision was crucial as it explicitly stated that any benefits not expressly provided for in the agreement are deemed purely voluntary acts of the company and their continuance does not create a binding obligation.