
MANILA, Philippines — The Supreme Court (SC) has affirmed the authority of the National Labor Relations Commission (NLRC) to enforce the terms of a Collective Bargaining Agreement (CBA) in cases involving unfair labor practices (ULP), siding with the commission’s decision against Guagua National Colleges (GNC).
In a decision penned by Associate Justice Japar B. Dimaampao, the SC’s Third Division upheld the NLRC’s order requiring GNC to pay agreed economic benefits to its employees, though it modified how the benefits should be computed.
The case stemmed from the stalled 2009 negotiations to renew the five-year CBA between GNC and its employees’ unions. Although GNC initially agreed to provide benefits such as rice subsidy, loyalty pay, and clothing allowance, it delayed signing the CBA draft. The unions later filed a notice of strike, accusing the school of bad faith and serious violations of the agreement. The Secretary of Labor and Employment intervened and referred the dispute to the NLRC for compulsory arbitration.
The NLRC ruled that GNC committed unfair labor practice by bargaining in bad faith and declared the final CBA draft as binding. It then ordered GNC to pay the benefits retroactively from 2009 to 2017.
GNC challenged the NLRC’s order, arguing that only voluntary arbitrators had jurisdiction to enforce CBA provisions. The Court of Appeals rejected this argument, and the SC affirmed the appellate court’s ruling.
The high court clarified that while voluntary arbitrators generally enforce CBA implementation, the NLRC may take over when violations rise to the level of ULP. It added that referring the matter to arbitrators after the NLRC had already resolved the issue would only delay justice and prolong disputes between the parties.
However, the SC ruled that the benefit computation ordered by the NLRC was inaccurate. It excluded the signing bonus from the computation and limited the covered period to the five-year term of the CBA from 2009 to 2014.





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