United CMC Textile Workers Union vs Labor Arbiter, L-70763, April 30, 1987; 149 SCRA 424

Posted by Pius Morados on

(Labor Standards – Payment of Christmas Bonus under the CBA; 13th month pay under PD 851 and the La Carlota doctrine)  

Facts: Petitioner union filed a complaint against CTMI for non-payment of the 1978 Christmas bonus of rank and file employees as provided in their CBA. The decision of the SC has become final and executory in favor of the petitioner union.

Subsequently, CTMI filed an appeal stating that the decision of the SC has become moot and academic by virtue of a previous jurisprudence (La Carlota) ruling that employers already paying the equivalent of the 13th month pay to their employees, such as Christmas bonus, are under no legal obligation to pay an additional month pay prescribed under PD 851. Respondent Labor Arbiter refused to continue with the execution of the decision contending that it has become moot and academic.

Issue:

  1. WON employer paying its employees the Christmas bonus under the CBA is no longer required to pay the 13th month pay provided under PD 851.
  2. WON the Carlota ruling is applicable in the case herein.

Held:

  1. Yes. 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. But it did provide, thus the intention is clear that said bonus is meant to be in addition to the legal requirement.
  2. No. La Carlota doctrine cannot be applied because judgments which had been long become final and executory can no longer be amended or modified by the courts. Such doctrine known as “the law of the case.”

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