Clark Development Corp. v. Association of CDC Supervisory Personnel Union, G.R. No. 207853, [March 30, 2022]

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Clark Development Corp. v. Association of CDC Supervisory Personnel Union

 G.R. No. 207853, [March 30, 2022]

THIRD, LOPEZ, M.

 

Collective Bargaining Agreement; Employee Union of GOCCs

 

Collective bargaining agreements, which violate laws or regulations, are void and cannot create rights or obligations. The right of government employees to self-organization and collective bargaining are subject to limitations and increases in salaries and benefits must comply with applicable laws and regulations, including those issued by the President.

 

The Clark Development Corporation (CDC), responsible for managing the Clark Special Economic Zone, renegotiated a Collective Bargaining Agreement (CBA) with its supervisory employees union, granting additional benefits. However, the Governance Commission for Government-Owned and-Controlled Corporations (GCG) opined that the CBA violated Executive Order (EO) No. 7 by granting increases in salaries and benefits without the President's authorization. Despite recommendations for deferment or renegotiation, CDC failed to implement the CBA, leading the union to file a complaint before the National Conciliation and Mediation Board. 

 

Whether the renegotiated CBA, which granted additional benefits to CDC's supervisory employees, is valid and enforceable despite the absence of the President's authorization as mandated by EO No. 7.

NO. The Court ruled that the renegotiated economic provisions of the CBA were void for violating EO No. 7, which imposed a moratorium on increases in salaries and benefits in government-owned corporations. The Court emphasized that the moratorium continued until specifically authorized by the President, and since there was no such authorization, the increases granted under the CBA were invalid. Furthermore, the Court rejected the presumption of the President's approval, noting that the law must be interpreted according to its plain meaning, and any doubts should not be resolved in favor of labor when the language of the law is unambiguous. Therefore, CDC had valid reasons not to implement the increases, as any contract violating the law is void and cannot create rights or obligations.

 

 

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