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GUAGUA NATIONAL COLLEGES V. GNCFLU [ G.R. No. 252101, March 05, 2025 ]

GUAGUA NATIONAL COLLEGES V. GNCFLU [ G.R. No. 252101, March 05, 2025 ]
Posted by:PJP
Interactive Case Summary: Guagua National Colleges v. GNC Unions

SUPREME COURT - THIRD DIVISION

[ G.R. No. 252101, March 05, 2025 ]

GUAGUA NATIONAL COLLEGES, PETITIONER, VS. GUAGUA NATIONAL COLLEGES FACULTY LABOR UNION, AND GUAGUA NATIONAL COLLEGES NON-TEACHING AND MAINTENANCE LABOR UNION, RESPONDENTS.

Case Summary: Unfair Labor Practice & CBA Execution

  • This case involves a long-running dispute where Guagua National Colleges (GNC) was found guilty of unfair labor practice for bargaining in bad faith with its employee unions. After the Supreme Court affirmed an earlier NLRC decision that imposed a Collective Bargaining Agreement (CBA) on the parties, the NLRC issued a writ of execution for the monetary benefits under that CBA. The Supreme Court upheld the NLRC's authority to execute the award but ruled that it exceeded its jurisdiction by computing benefits beyond the CBA's five-year effectivity period. The case was remanded for a re-computation limited to the correct CBA period.
  • The Parties: Guagua National Colleges (GNC) and its two employee unions, one for faculty and one for non-teaching staff.
  • Bad Faith Bargaining: In 2009, during negotiations for a new CBA, GNC repeatedly stalled, failed to provide counterproposals, and backed out of agreements, prompting the unions to file a notice of strike.
  • Imposed CBA: The dispute went to compulsory arbitration. In 2011, the NLRC found GNC guilty of unfair labor practice and imposed the unions' final draft as the official CBA for the period June 1, 2009 to May 31, 2014.
  • Motion for Execution: After the Supreme Court affirmed the NLRC's decision in 2016, the unions filed a motion for execution in 2017 to claim the unimplemented economic benefits under the imposed CBA.
  • NLRC Writ of Execution: The NLRC granted the motion and issued a writ of execution for PHP 4,676,288.32, covering benefits like rice subsidy, longevity pay, and signing bonus. The computation covered the period from June 2009 *up to 2017*.
  • Court of Appeals (CA) Ruling: GNC challenged the writ. The CA upheld the NLRC's authority to execute the award but excluded the "signing bonus" from the computation, as there was no goodwill between the parties.
  • Does the NLRC have the authority to issue a writ of execution for monetary benefits based on a CBA it imposed in a compulsory arbitration case, even if the decision did not specify a monetary award?
  • Did the NLRC exceed its jurisdiction by computing the benefits beyond the CBA's effectivity period?

The Supreme Court PARTLY GRANTED the petition, affirming the NLRC's authority but modifying the scope of the award.

  • NLRC Has Jurisdiction to Execute: The Court affirmed that the NLRC has incidental jurisdiction to enforce its own final and executory decisions. Since the NLRC's 2011 decision imposed the CBA, it has the authority to execute the economic provisions of that CBA. Forcing the parties to go through another grievance and arbitration process would promote multiplicity of suits.
  • Execution Exceeded Scope: The NLRC committed grave abuse of discretion by computing benefits up to 2017. The imposed CBA was only effective until May 31, 2014. By extending the award beyond this date, the NLRC improperly altered the terms of its own final and executory decision, violating the doctrine of immutability of judgment.
  • Remand for Re-computation: The case was remanded to the NLRC with the specific instruction to re-compute the monetary award, limiting it to the benefits due only within the CBA's effectivity period of June 1, 2009 to May 31, 2014.
  • Incidental Jurisdiction: The grant of jurisdiction to a tribunal (like the NLRC) implies the necessary powers to enforce its judgments and mandates, including executing the economic provisions of a CBA it has imposed.
  • Immutability of Judgment: A final and executory decision cannot be altered, amended, or modified, even if the modification is meant to correct a perceived error. An order of execution must conform strictly to the dispositive portion of the decision.
  • Signing Bonus: A signing bonus is a grant motivated by goodwill from a *successfully negotiated* CBA. It cannot be awarded when a CBA is imposed by a labor tribunal due to a bargaining deadlock or bad faith.