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Special Holiday Pay Dispute Ruling

RFM-Flour Division and SFI Feeds Division v. KAMPI-NAFLU-KMU and SUMAPI-NAFLU-KMU involved a dispute over holiday pay according to collective bargaining agreements between the companies and unions. The agreements stated employees should be paid on special holidays declared by the government. On December 31st, which was declared a special holiday but fell on a Sunday, the companies refused to pay, claiming it was a rest day. The unions filed a case which ultimately went to the Supreme Court. The Supreme Court ruled in favor of the unions, stating that if no doubt exists in the terms of the agreement, the literal meaning should be used. As such, employees must be paid

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43 views1 page

Special Holiday Pay Dispute Ruling

RFM-Flour Division and SFI Feeds Division v. KAMPI-NAFLU-KMU and SUMAPI-NAFLU-KMU involved a dispute over holiday pay according to collective bargaining agreements between the companies and unions. The agreements stated employees should be paid on special holidays declared by the government. On December 31st, which was declared a special holiday but fell on a Sunday, the companies refused to pay, claiming it was a rest day. The unions filed a case which ultimately went to the Supreme Court. The Supreme Court ruled in favor of the unions, stating that if no doubt exists in the terms of the agreement, the literal meaning should be used. As such, employees must be paid

Uploaded by

NN DDL
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
  • FACTS

RFM-Flour Division and SFI Feeds Division v.

KAMPI-NAFLU-KMU and SUMAPI-NAFLU-KMU

FACTS
The Flour and SFI Feeds divisions of RFM entered into similar CBAs with their respective labor unions
KAMPI and SUMAPI effective for 5 years.

Section 3. Special Holidays with Pay.


The COMPANY agrees to make payment to all daily paid employees, in respect of
any of the days enumerated hereunto if declared as special holidays by the national
government:
a) Black Saturday
b) November 1
c) December 31
The compensation rate shall be the regular rate. Any work beyond eight (8) hours
shall be paid the standard ordinary premium. (Emphasis and underscoring supplied)
During the CBAs first year, Dec. 31 was a Sunday + declared as a special holiday.
o Unions claimed for pay, RFM refused, averring that it was a rest day deadlocked, submitted to
VA.
VA ruled in favor of unions
MR: denied
CA: affirmed
o Held that if it was indeed FRMs intent to pay salaries of daily-paid workers during special
holiday, even if unworked, the CBA would have explicitly said so.
o Kimberly Clark v. Lorredo is INAPPLICABLE re: conflict of words in CBA and intention of parties
simply because there was no provision in the CBA that would result to absurd interpretations v.
intent.
o Also awarded attorneys fees
RFM: CBA protects EE from reduction of take-home pay, thus it was not meant to remunerate
Sundays, nor increase salaries

ISSUE + RULING
Is the remuneration for special holidays falling on Sundays covered by the CBA? YES.
If no doubt as to terms of CBA = literal meaning is used.
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.
o Holiday pay is a legislated benefit enacted as part of the Constitutional imperative that the
State shall afford protection to labor.
o 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.
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: parties failed to foresee a situation where the special holiday would fall on a rest day.
o SC: So?? Doubt in the interpretation of any law or provision affecting labor should be
interpreted in favor of labor.

RFM-Flour Division and SFI Feeds Division v. KAMPI-NAFLU-KMU and SUMAPI-NAFLU-KMU FACTS  The Flour and SFI Feeds divisi

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