AUTHOR : TIGLAO Royal Plant Workers Union v. Coca-Cola Bottlers Philippines, Inc. – Cebu Cebu Plant NOTES: G.R. No. 198783 | 15 April 2013 TOPIC: Limits of MP Digest focused on the MP aspect. To check on the procedural aspect, feel free PONENTE: J. Mendoza to check on the full text. Didn’t include because it’ll be longer CASE LAW/ DOCTRINE: Law; Management Prerogatives;. — The The Court has held that management is free to regulate, according to its own discr etion and judgment, all aspects of employment, Labor Law; including hiring, work assignments, working methods, time, place, and manner of work, processes to be followed, supervision of workers, working regulations, transfer of employees, work supervision, lay-off of workers, and discipline, dismissal and recall of workers. The exercise of management prerogative, however, is not abso lute as it must be exercised in good faith and with due re gard to the rights of labor. Standards; There There is no law that requires employers to provide chairs for bottling operators. The Labor Code, specifically Article 132 th ereof, only requires employers Labor Standards; to provide seats for women. No similar requirement is mandated for men or male workers. FACTS: Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation engaged in the manufacture, sale and distribution of softdrink products. It has several bottling plants in the Philippines, one one of which is in Cebu City. In each bottling plant, there are bottling operators. For example, example, in Cebu City, there are 20 bottling operators who work for its Bottling Line 1 while there are 12-14 bottling operators who work for Bottle Line 2. All of them are male and they are members of the Royal Plant Workers Union (ROPWU). The bottling operators work in two shifts. The first is from 8-5 while the second is from 5 PM until the production operations is finished. Hence, the second shift varies and may end beyond eight hours. However, if the operators work beyond eight hours, he is compensated with overtime pay. In Bottling Line 1, 10 operators for each shift while in Bottline Line 2, 6 -7 operators per shift. Each shift has rotations of work and break time. Before September 2008, the rotation is: after 2 ½ hours of work, operators are given a 30-minute break and this goes on until the shift ends. In Sept. 2008 up to the present, the rotation has changed and operators are now given a 30 minute break after 1 ½ hours of work. In 1974, the operators of Bottling Line 2 were provided chairs upon request. In 1988, the operators of Bottling Lin Linee 1 followed suit. In Sept 2008, the c hairs were removed pursuant to a national directive of CCBPI. The directive was in line to the “I Operate, I Maintain, I Clean” program of CCBPI wherein the operators are given the responsibility to keep the machinery and equipment assigned to him clean and safe. The program focuses the duty of operators to constantly move in the exercise of their duties. Since they are expected to constantly move, the operators no longer need a chair. CCBPI explained that the removal of the chairs is implemented so that operators would avoid sleeping in order to prevent personal injuries, since if they fall asleep and the machines are moving, it might result to injury. The operators, however, took issue with the removal of the chairs. Through the ROPWU, they initiated a grievance machinery of the CBA in November 2008. Sadly, they only reached a deadlock with CCBPI, insisting on the removal of the chairs. Thus, ROPWU initiated arbitration proceedings. Arbitration Committee Decision: In favor of ROPWU stating that the use of chairs by the operators had been a c ompany practice for 34 years in Bottling Line 2 and 20 years in Bottling Line 1 and that it ripened into a benefit enjoyed by the employees, thus, it cannot be reduced by the employer under Article 100 of the Labor Code. CA Decision: Reversed the Arbitration Decision. CA held that the removal of the chairs by the CCBPI is within the province of management prerogatives and that it was part of his inherent right to control and manage its enterprise effectively; and that since it was the employer’s discretion to constantly develop measures or means to optimize the efficiency of its employees, it was appropriate that it should be given wide latitude in exercising it. CA further added that the CCBPI complied with the conditions of a valid exercise of a management prerogative when it decided to remove the chairs. The removal of the chairs was motivated by the best intentions for both the Union and CCBPI. Without the chairs, the operators could efficiently supervise these machineries’ operations. Hence, this appeal. ISSUE(S): W/N the CCBPI’s decision to remove the chairs was within its management prerogative. HELD: Yes. Petition is denied. RATIO:
It is a valid exercise of management prerogative. The Court has held that management is free to regulate, according to its own discretion and judgment, all aspects of employment, including hiring, work assignments, working methods, time, place and manner of work, processes to be followed, supervision of workers, working regulations, transfer of employees, work supervision, layoff workers, and discipline, dismissal and recall of workers.
The exercise of management prerogative, however, is not absolute as it must be exercised in good faith and with due regard to the rights of labor. It cannot be denied that CCBPI removed the chairs in line with its national directive and that the chairs were not removed indiscriminately. In fact, the removal of the chairs was compensated by: a) reduction of the operating hours, and b) an increase o f the break period. The decision to remove the chairs was done with good intentions as CCBPI wanted to avoid instances of operators sleeping on the job while in the performance of their duties and responsibilities. In short, the removal of the chairs was design to increase work efficiency. The fact that there is no proof of any operator sleeping on the job holds no water. There is no guarantee that such incident would never happen as sitting on a chair is relaxing. Ultimate purpose is to promote work efficiency. Further, no labor law requires employers to provide chairs for bottling operators. The CA was c orrect in saying that Article 132 of the Labor Code only requires e mployers to provide seats for women. No violation of the Health, Safety and Social Welfare Benefit Provisions of the Labor Code because the removal of the chairs resulted in the increase in the rest period. The chairs cannot be considered to form part of the benefits under Article 100 of the Labor Code. The term benefits refers to monetary benefits or privileges given to the employee with monetary equivalents such as employee’s wage, salary or c ompensation. Jurisprudence recognizes the exercise of management prerogatives. Labor laws also discourage interference with an employer’s judgment in the conduct of its business. Thus, the Court often declines to interfere in legitimate business decisions of employers. The law must protected not only the welfare of the employees, but also the right of the employers.
