G.R. No. 119205 – 351 Phil. 1013 – 289 SCRA 86 – Labor Law – Labor Relations – Management Prerogative
The workers of Sime Darby Pilipinas, Inc. have an 8-hour daily schedule which starts at 7:45 am and ends at 3:45 pm. They have a 30-minute paid lunch break but during said break, they are “on call” hence can be pulled out at any time if the need arises. However, in August 1992, Sime Darby issued a memorandum which changed the working schedule from 7:45 am to 4:45 pm. This time, all employees will have a one-hour lunch break which is no longer paid but at the same time, employees will no longer be “on call.”
The labor union (Sime Darby Salaried Employees Association) opposed the revised schedule. The union insists that the scrapping of the 30-minute paid lunch break is a diminution of benefits.
ISSUE: Whether or not the new memorandum constitutes diminution of benefits.
HELD: No. It is a valid exercise of management prerogative. In the old schedule, the workers were paid for eight hours and included in that is the paid 30-minute lunch break. In the new schedule, the workers are still paid for 8 hours, so there’s really no diminution of benefit. It would be unfair on the part of Sime Darby for the workers to be paid still for their new 1 hour break even though this time they are no longer “on call.” If that would be the case, the workers will be unjustly enriched.
In this case, it is the right of Sime Darby as the employer to change the work schedules of the workers so long as such prerogative is exercised in good faith for the advancement of the employer’s interest and not for the purpose of defeating or circumventing the rights of the employees under special laws or under valid agreements. Further, the new work schedule also benefits the workers as they can now enjoy a longer lunch break of 1 hour instead of the old 30-minute break and they can enjoy it without being interrupted as they’re no longer on call. For a full one-hour undisturbed lunch break, the employees can freely and effectively use this hour not only for eating but also for their rest and comfort which are conducive to more efficiency and better performance in their work.
