SCA HYGIENE PRODUCTS CORPORATION
But the company did
EMPLOYEES ASSOCIATION-FFW, Petitioner,
vs.
SCA HYGIENE PRODUCTS
CORPORATION, Respondent.
FACTS:
Respondent SCA Hygiene is a domestic
corporation which manufactures and sells
industrial paper, tissue and the like. It had an
existing CBA with 2 Unions: the Monthly
Employees Union and the petitioner Daily
Employees Union (aka SCAHPCEA-FFW). The 2
represent the monthly and daily paid rank-and-file
employees, respectively.
The 2 CBAs contained Job Evaluation provision,
stating that the company will conduct job
evaluation when deemed necessary, to be
conducted by a 3rd party, and that the company
will involve the union members representatives in
writing the job description.
In 2003, the company conducted a company-wide
job evaluation through Mercer HR Consulting, an
independent consultant. On Feb 2004, Mercer
HRC reported to the company the results of the
job evaluation. Because of this, the company
adopted 8 new job grade levels:
Job Grade
Employee[s’] Category
Level
8 Executive
7 Executive
6 Department Manager
5 Unit Manager
4 Unit Manager
Management Team
3 for. He held that the 22 employees were
Member
2 Rank-and-File
1 Rank-and-File
So in effect, they made reclassifications for the
jobs.
22 daily paid rank-and-file employees were
informed that their positions had been classified
as Job Grade Level 2, from Level 1.
Because of this, the Monthly Union demanded that
those 22 daily paid workers be given
conversion/promotion increases and salary
increases from the time the job evaluation was
completed because in effect, their positions had
been converted to a higher job grade level
amounting to a promotion.
not respond. (So in short, feel nila yung pag
upgrade sa 22 daily workers to Level 2, and effect
ay prinomote sila so nanghihingi sila ng extra
pay).
The 2 unions submitted their grievance for
mediation but there was failure to reach an
amicable settlement.
The unions claimed that the 22 daily paid rank-
and-file employees were entitled to conversion
increase since Job Grade Level 2 positions are
meant for monthly paid rank-and-file employees
and along with the conversion, said employees
were allegedly given additional job descriptions.
They claimed that they were entitled to promotion
increase as well, since such is the company
practice everytime an employee’s rank is
converted to a higher job grade level.
They compare the increases given to those
employees raised from Level 2 to Level 3 because
they were granted the benefits concomitant to
their new positions.
The company responded that the job evaluation
was merely a process of determining the relative
contribution and value of the positions in its
operations and does not provide for any
adjustment in the salaries of the covered
employees. Meaning, it is not a promotion and
they are not entitled to salary and conversion
increases. The company contends that the 22 R&F
employees still occupy the same positions that
they were occupying prior to the job
evaluation. There was no promotion. And the
Level 3 positions were justified because they were
the ones promoted to a higher position.
The voluntary arbitrator ruled in favour of the
unions and awarded the increases being prayed
performing duties of a monthly paid rank-and-file
employee. The employees were therefore entitled
to conversion increase.
However, the CA on appeal ruled in favour of the
company. It held that the job evaluation was
conducted as a reorganization process to
standardize the company’s organizational set-up.
The CBAs merely provided the procedure for the
implementation of the job evaluation. It did not
specifically state that the covered employees are
entitled to any salary adjustment after the job
evaluation. Hence, in the absence of any law or
agreement between the parties, any conversion
much less promotion is left entirely to
respondent’s sound discretion.
Petitioner contends that the 22 daily paid rank- Job Grade Level 1 to Job Grade Level 2 takes
and-file employees were promoted after the job place, a promotion automatically ensues.
evaluation. The company counters that the 22
daily paid rank-and-file employees were not Those who were elevated to Job Grade Level 3
promoted since they continue to occupy the same positions were rightfully given the additional
positions that they were occupying prior to the job benefits since they have become managerial
evaluation. employees, specifically Management Team
Members, and not merely rank-and-file
ISSUE: W/N the 22 daily paid rank and file employees. The same cannot be said of the
employees were promoted when their twenty-two (22) daily paid rank-and-file
positions were converted from Job Grade employees involved in the case at bar.
Level 1 to Level 2? And W/N they are entitled
to a conversion increase. Petitioner also argues that said employees are
entitled to conversion increase since such has
HELD/RATIO: The company did not act in bad been the company practice everytime an
faith. There was no circumvention of the law employee’s rank is converted to a higher job
hence the job evaluation was merely a grade level. However, this was not proven.
management prerogative. No conversion increase,
no promotion.

It is a well-settled rule that labor laws do not

authorize interference with the employer's
judgment in the conduct of its business. The
hiring, firing, transfer, demotion, and promotion of
employees have been traditionally identified as a
management prerogative subject to limitations
found in the law, a collective bargaining
agreement, or in general principles of fair play and
justice.

The Court has recognized and affirmed the

prerogative of management to implement a job
evaluation program or a re-organization for as
long as it is not contrary to law, morals or public
policy.

The job evaluation program was undertaken to

streamline respondent’s operations and to place
its employees in their proper positions or
groupings. A perusal of the CBAs of the parties
showed that, as correctly ruled by the Court of
Appeals, it merely provided the procedure for the
implementation of the job evaluation and did not
guarantee any adjustment in the salaries of the
employees.

Based on the eight new job grade levels which

respondent adopted after the job evaluation, Job
Grade Levels 1 and 2 positions are both
categorized as rank-and-file employees. Said
employees continued to occupy the same
positions they were occupying prior to the job
evaluation. Moreover, their job titles remained the
same and they were not given additional duties
and responsibilities.

There is also no evidence to show that Job Grade

Levels 1 and 2 positions are confined only to daily
and monthly paid rank-and-file employees,
respectively, such that when a conversion from