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    8.2.2. Universal Corn Products v. NLRC, August 21, 1987

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    JONA PHOEBE MANGALINDAN
    This case involves a dispute over whether a company still had to pay an annual Christmas bonus to employees in addition to the mandated 13th month pay required by law. The collective bargaining agreement previously required the company to pay a 7-day Christmas bonus to employees with at least one year of continuous service. However, a new agreement did not mention the bonus. The Court ruled that the 13th month pay did not preclude the Christmas bonus because the bonus was intended to reward longevity and was included in the previous CBA, so it remained an obligation separate from the legal 13th month pay requirement. Therefore, the company still had to pay the Christmas bonus to eligible employees.

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    8.2.2. Universal Corn Products v. NLRC, August 21, 1987

    Uploaded by

    JONA PHOEBE MANGALINDAN
    68 views2 pages
    This case involves a dispute over whether a company still had to pay an annual Christmas bonus to employees in addition to the mandated 13th month pay required by law. The collective bargaining agreement previously required the company to pay a 7-day Christmas bonus to employees with at least one year of continuous service. However, a new agreement did not mention the bonus. The Court ruled that the 13th month pay did not preclude the Christmas bonus because the bonus was intended to reward longevity and was included in the previous CBA, so it remained an obligation separate from the legal 13th month pay requirement. Therefore, the company still had to pay the Christmas bonus to eligible employees.

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    This case involves a dispute over whether a company still had to pay an annual Christmas bonus to employees in addition to the mandated 13th month pay required by law. The collective bargaining agreement previously required the company to pay a 7-day Christmas bonus to employees with at least one year of continuous service. However, a new agreement did not mention the bonus. The Court ruled that the 13th month pay did not preclude the Christmas bonus because the bonus was intended to reward longevity and was included in the previous CBA, so it remained an obligation separate from the legal 13th month pay requirement. Therefore, the company still had to pay the Christmas bonus to eligible employees.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    68 views2 pages

    8.2.2. Universal Corn Products v. NLRC, August 21, 1987

    Uploaded by

    JONA PHOEBE MANGALINDAN
    This case involves a dispute over whether a company still had to pay an annual Christmas bonus to employees in addition to the mandated 13th month pay required by law. The collective bargaining agreement previously required the company to pay a 7-day Christmas bonus to employees with at least one year of continuous service. However, a new agreement did not mention the bonus. The Court ruled that the 13th month pay did not preclude the Christmas bonus because the bonus was intended to reward longevity and was included in the previous CBA, so it remained an obligation separate from the legal 13th month pay requirement. Therefore, the company still had to pay the Christmas bonus to eligible employees.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Mangalindan, Jona Phoebe A.

    G.R. No. L-60337 August 21, 1987

    UNIVERSAL CORN PRODUCTS (A DIVISION OF UNIVERSAL ROBINA


    CORPORATION), petitioner,
    vs.
    THE NATIONAL LABOR RELATIONS COMMISSION and JOSE ARMAS, et
    al, respondents

    FACTS:

     Sometime in May, 1972, petitioner and the Universal Corn Products Workers Union
    entered into a collective bargaining agreement, with a duration of three years,it was
    provided that the COMPANY agrees to grant all regular workers within the
    bargaining unit with at least one (1) year of continuous service, a Christmas bonus
    equivalent to the regular wages for seven (7) working days.
     The collective bargaining agreement expired without being renewed.
     On June 1, 1979, the parties entered into an "addendum" stipulating certain wage
    increases. They entered into a new collective bargaining agreement. The new
    agreement did not refer to the "Christmas bonus" paid but dealt only with salary
    adjustments.
     According to the petitioner, the new agreements deliberately excluded the grant of
    Christmas bonus with the enactment of Presidential Decree No. 851. petitioner
    invokes National Federation of Sugar Workers (NFSW) v. Ovejera, that Presidential
    Decree No. 851, the 13th-month pay law, does not cover employers already paying
    their employees an "equivalent" to the 13th month pay.
     For failure of the petitioner to pay the seven-day Christmas bonus, the union went to
    the labor arbiter for relief.
     Labor arbiter ruled that the payment of the 13th month pay precluded the payment of
    further Christmas bonus.
     The NLRC set aside the decision of the labor arbiter

    ISSUE :

     WON the payment of the 13th month pay precluded the payment of further Christmas
    bonus.

    RULING:

     NO, The Court applied United CMC Textile Workers Union v. Valenzuela , it held:

    ... If the Christmas bonus was included in the 13th month pay, then there would
    be no need for having a specific provision on Christmas bonus in the CBA. The
    intention is clear therefore that the bonus provided in the CBA was meant to
    be in addition to the legal requirement. The classification of the company's
    workers in the CBA according to their years of service supports the
    allegation that the reason for the payment of bonus was to give bigger award
    to the senior employees-a purpose which is not found by P.D. 851.

    A bonus under the CBA is an obligation created by the contract between the
    management and workers while the 13th month pay is mandated by the law
    (P. D. 851). 

     Like the Valenzuela, agreement, the Christmas bonus provided in the collective


    bargaining agreement accords a reward, in this case, for loyalty, to certain
    employees. This is evident from the stipulation granting the bonus in question to
    workers "with at least one (1) year of continuous service." As we said in Valenzuela"
    this is "a purpose not found in P.D. 851." 

     WHEREFORE, premises considered, the petition is hereby DISMISSED. The Decision


    of the public respondent NLRC promulgated on February 11, 1982, and its Resolution
    dated March 23, 1982, are hereby AFFIRMED. The temporary restraining order issued
    on May 19, 1982 is LIFTED.

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