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SIME DARBY PILIPINAS v. NLRC

FACTS:

Sime Darby Pilipinas, Inc. (petitioner) is a company engaged in the manufacture of automotive tires, tubes, and other rubber products. Sime Darby Salaried Employees Association (ALU-TUCP) (private respondent) is an association of monthly salaried employees of petitioner at its Marikina factory. Prior to the present controversy, all company factory workers in Marikina, including members of private respondent union, worked from 7:45 a.m. to 3:45 p.m. with a 30-minute paid "on call" lunch break.

On 14 August 1992, petitioner issued a memorandum changing the work schedule of its employees, effective 14 September 1992. The new work schedule was from 7:45 a.m. to 4:45 p.m. on weekdays and 7:45 a.m. to 11:45 p.m. on Saturdays. The memorandum also provided for a ten-minute coffee break and a one-hour lunch break between 12:00 noon and 1:00 p.m. The new schedule did not include the 30-minute paid "on call" lunch break.

Private respondent filed a complaint alleging unfair labor practice, discrimination, and evasion of liability. The Labor Arbiter dismissed the complaint, ruling that the change in the work schedule and the elimination of the 30-minute paid lunch break did not violate the Labor Code as the working time did not exceed eight hours. Private respondent appealed to the National Labor Relations Commission (NLRC), which initially dismissed the appeal but later reversed its decision upon private respondent's motion for reconsideration.

ISSUES:

  1. Whether the act of management in revising the work schedule of its employees and discarding their paid lunch break constitutes unfair labor practice.

  2. Whether there was a diminution of benefits when the 30-minute paid lunch break was eliminated.

  3. Whether the decision in the earlier Sime Darby case is applicable to the instant case.

  4. Whether the petitioner's inherent management prerogative in determining and fixing the work schedule of its employees was ignored.

RULING:

  1. No, the act of management in revising the work schedule and eliminating the paid lunch break does not constitute unfair labor practice as it applies to all employees similarly situated and does not prejudice the right to self-organization.

  2. No, there was no diminution of benefits because the new work schedule fully complies with the daily work period of eight hours as required by law.

  3. No, the decision in the earlier Sime Darby case is not applicable to the instant case because the earlier case involved discrimination among employees, whereas the current case involves a uniform work schedule change without discrimination.

  4. Yes, the petitioner's inherent management prerogative in determining the work schedule of its employees should be upheld, provided it is exercised in good faith for the advancement of the employer's interest and not to defeat or circumvent the rights of the employees.

PRINCIPLES:

  • Management Prerogative: Employers have the right to regulate, according to their discretion and judgment, all aspects of employment, including work schedules, provided it is done in good faith.

  • Diminution of Benefits: Changing work schedules to increase efficiency, where the period worked remains compliant with labor laws, does not constitute a diminution of benefits.

  • Equality in Application: Changes in work schedules must apply equally to all employees in the same line of work to avoid discrimination.

  • Legal Precedent: Prior case law involving discriminatory practices does not automatically apply to cases involving uniform changes in work schedules.