DIGEST: Royal Plant Workers Union v. Coca-Cola Bottlers Philippines, Inc. – Cebu Plant, G.R.
No. 198783, 15 April 2013
Royal Plant Workers Union v. Coca-Cola Bottlers Philippines, Inc. – Cebu Plant
15 April 2013 G.R. No. 198783 J. TIGLAO
Provisions/Concepts/Doctrines and How Applied to the Case
Labor Law; Management Prerogatives;.—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, lay-off of 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.
Labor Standards; There is no law that requires employers to provide chairs for bottling operators. The Labor
Code, specifically Article 132 thereof, only requires employers 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 of which is in Cebu City. In
each bottling plant, there are bottling operators. For 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
Line 1 followed suit. In Sept 2008, the chairs 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
company 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 (relevant to the syllabus)
W/N the CCBPI’s decision to remove the chairs was within its management prerogative. --Yes Petition is denied.
RULING (include how the law was applied)
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, lay-off 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 of 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.
b) 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 correct in saying that Article 132 of the Labor Code only requires employers 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 compensation. 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.
DISPOSITIVE
WHEREFORE, premises considered, we hereby DENY the petition. We PARTIALLY AFFIRM the May 27, 2008
decision of the Court of Appeals in CA-G.R. SP No. 119715. Petitioner Ruben Jordan is hereby ordered to RETURN TO
WORK within fifteen days from the receipt of this Decision. Respondent Grandeur Security and Services, Inc. is
likewise ordered to ACCEPT petitioner Ruben Jordan. No costs.
ADDITIONAL NOTES
On LA’s May 27, 2008 Contradictory Judgments
It does not escape the Court’s attention that the dispositive part of the May 27, 2008 decision contains two
contradictory judgments. The dispositive part states that Jordan’s complaint for illegal dismissal is dismissed for lack
of merit. In the same breath, the LA ordered Grandeur Security to reinstate Jordan in employment, whether physically
or in the payroll. These conflicting judgments are absurd because an employee who has not been dismissed, much
less illegally dismissed, cannot be reinstated.
As a rule, the court’s resolution in a given issue is embodied in the decision’s dispositive part. The dispositive part is
the controlling factor on the settlement of parties’ rights, notwithstanding the confusing statement in the body of the
decision or order. However, this rule only applies when the decision’s dispositive part is definite, clear and
unequivocal. Where a doubt or uncertainty exists between the dispositive part and the body of the decision,
the Court must harmonize the former with the latter in order to give effect to the decision’s intention,
purpose and substantive terms.
