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CBA Holiday Pay Dispute Resolution

RFM Corporation entered into collective bargaining agreements (CBAs) with two unions requiring payment to daily-paid employees on declared special holidays, including December 31, 2000 which fell on a Sunday. When RFM refused to pay the employees, citing it was a rest day, the unions filed for voluntary arbitration. The arbitrator and Court of Appeals sided with the unions, finding the CBAs clearly required payment. The Supreme Court affirmed, stating the CBAs were clear and intended to provide holiday pay as a labor protection, regardless of the day falling on a rest day or not.

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393 views2 pages

CBA Holiday Pay Dispute Resolution

RFM Corporation entered into collective bargaining agreements (CBAs) with two unions requiring payment to daily-paid employees on declared special holidays, including December 31, 2000 which fell on a Sunday. When RFM refused to pay the employees, citing it was a rest day, the unions filed for voluntary arbitration. The arbitrator and Court of Appeals sided with the unions, finding the CBAs clearly required payment. The Supreme Court affirmed, stating the CBAs were clear and intended to provide holiday pay as a labor protection, regardless of the day falling on a rest day or not.

Uploaded by

attyalan
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
  • Labor Law Case

Labor Law RFM CORPORATION-FLOUR DIVISION and SFI FEEDS DIVISION v.

KASAPIAN NG MANGGA-GAWANG PINAGKAISARFM (KAMPI-NAFLU-KMU) andSANDIGAN AT UGNAYAN NG MANGGAGAWANG PINAGKAISA-SFI (SUMAPI-NAFLU-KMU) G. R. No. 162324 February 4, 2009 Carpio Morales, J. FACTS Petitioner RFM Corporation, a domestic corporation entered into collective bargaining agreements (CBAs) with the Kasapian ng Manggagawang Pinagkaisa-RFM (KAMPI-NAFLU-KMU) and Sandigan at Ugnayanng Manggagawang Pinagkaisa-SFI (SUMAPINAFLU-KMU).Under the CBA, RFM agreed to make payment to all daily paid employees on Black Saturday, November 1and December 31 if declared as special holidays by the national government. During the first year of the effectivity of the CBAs in 2000, December 31which fell on a Sunday was declared by the national government as a special holiday. Respondent unions thus claimed payment of their members salaries, invoking the CBA provision. RFM refused the claims for payment, averring that December 31, 2000 was not compensable as it was a rest day. The controversy resulted in a deadlock, drawing the parties to submit the same for voluntary arbitration. The Voluntary Arbitrator (VA) declared that the provision of the CBA is clear, ruling in favor of KAMPI-NAFLU-KMU and SUMAPI-NAFLU-KMU and ordered RFM to pay their salaries. The Court of Appeals(CA) affirmed the decision. ISSUE Whether or not the employees are entitled to the questioned salary according to the provision of the CBA. RULING If the terms of a CBA are clear and have no doubt upon the intention of the contracting parties, as in the herein questioned provision, the literal meaning thereof shall prevail. That is settled.

As such, the daily-paid employees must be paid their regular salaries on the holidays which are so declared by the national government, regardless of whether they fall on rest days. Holiday pay is a legislated benefit enacted as part of the Constitutional imperative that the State shall afford protection to labor. Its purpose is not merely "to prevent diminution of the monthly income of the workers on account of work interruptions. In other words, although the worker is forced to take a rest, he earns what he should earn, that is, his holiday pay." The CBA is the law between the parties, hence, they are obliged to comply with its provisions. Indeed, if petitioner and respondents intended the provision in question to cover payment only during holidays falling on work or weekdays, it should have been so incorporated therein. RFM maintains, however, that the parties failed to foresee a situation where the special holiday would fall on a rest day. The Court is not persuaded. The Labor Code specifically enjoins that in case of doubt in the interpretation of any law or provision affecting labor, it should be interpreted in favor of labor.

Labor Law RFM CORPORATION-FLOUR DIVISION and SFI FEEDS DIVISION v.KASAPIAN NG MANGGA-GAWANG PINAGKAISA- RFM (KAMPI-NAFLU-KMU
As such, the daily-paid employees must be paid their regular salaries on the holidays which are so declared by the

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