ROYAL PLANT WORKERS UNION vs. COCA-COLA BOTTLERS PHILIPPINES, INC.-CEBU PLANT

G.R. No. 198783 April 15, 2013

Management Prerogative

Facts: Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation engaged in the manufacture, sale and distribution of softdrink products. The bottling operators work in two shifts. The first shift is from 8 a.m. to 5 p.m. and the second shift is from 5 p.m. up to the time production operations is finished. In 1974, the bottling operators of then Bottling Line 2 were provided with chairs upon their request. In 1988, the bottling operators of then Bottling Line 1 followed suit and asked to be provided also with chairs. Their request was likewise granted. Sometime in September 2008, the chairs provided for the operators were removed pursuant to a national directive of petitioner. This directive is in line with the "I Operate, I Maintain, I Clean" program of petitioner for bottling operators. The program reinforces the task of bottling operators to constantly move about in the performance of their duties and responsibilities. 

The bottling operators took issue with the removal of the chairs. Petitioner argued that the removal of the chairs is valid as it is a legitimate exercise of management prerogative, it does not violate the Labor Code and it does not violate the CBA it contracted with respondent. On the other hand, respondent espoused the contrary view. It contended that the bottling operators have been performing their assigned duties satisfactorily with the presence of the chairs; the removal of the chairs constitutes a violation of the Occupational Health and Safety Standards, the policy of the State to assure the right of workers to just and humane conditions of work as stated in Article 3 of the Labor Code and the Global Workplace Rights Policy.

Issue: Whether the removal of the chairs from the manufacturing/production lines by CCBPI is a valid exercise of management prerogatives

Held: Yes. In the present controversy, it cannot be denied that CCBPI removed the operators’ chairs pursuant to a national directive and in line with its "I Operate, I Maintain, I Clean" program, launched to enable the Union to perform their duties and responsibilities more efficiently. The removal of the chairs was designed to increase work efficiency. Hence, CCBPI’s exercise of its management prerogative was made in good faith without doing any harm to the workers’ rights. 

WHEREFORE, the petition is DENIED.