Facts:

The case of "ABS-CBN IJM Workers Union vs. ABS-CBN Corporation" (G.R. No. 202131) revolves around a dispute involving allegedly irregular employment relationships concerning IJM workers at ABS-CBN Corporation. The petitioner, ABS-CBN IJM Workers Union (AIWU), sought to challenge the dismissal of their petition for a certification election. ABS-CBN Corporation, formerly known as ABS-CBN Broadcasting Corporation, is a domestic corporation engaged in radio and television broadcasting. In 2002, ABS-CBN implemented the Internal Job Market System (IJM), enabling workers to be listed based on their skills. The workers under this system included various technical staff essential to broadcasting.

On November 23, 2009, AIWU filed a petition with the Bureau of Labor Relations (BLR) to conduct a certification election, claiming to represent 1,101 employees. They argued that no existing exclusive bargaining agent was certified for these workers and that their membership support was

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Facts:

Background of the Parties and Employment System

• ABS-CBN Corporation is a domestic broadcasting company engaged in television and radio content production.
• In 2002, ABS-CBN implemented the Internal Job Market (IJM) System, a database listing accredited technical and creative manpower along with their competency ratings and professional rates.
• Workers hired through the IJM System, including cameramen, technical directors, editors, and others, became known as IJM workers.

Formation of the Union and Initiation of the Certification Election

• The ABS-CBN IJM Workers Union (AIWU) was formed by the IJM workers and registered with the Department of Labor.
• On November 23, 2009, AIWU, through its president, filed a petition before the Bureau of Labor Relations requesting a certification election to represent 1,101 IJM workers.
• The petition was supported by 369 signatures, representing 33.51% of the total bargaining unit, and was docketed as NCR-OD-M-0911-006.

Contesting the Employer-Employee Relationship

• ABS-CBN argued in its December 18, 2009 Comment that there was no employer-employee relationship between the IJM workers and itself, emphasizing that it would not participate in the certification election process.
• ABS-CBN cited prior National Labor Relations Commission (NLRC) decisions in the Payonan and Jalog cases, which found no such employment relationship for part of the petition’s signatories.
• The union, however, maintained that its members performed functions necessary to ABS-CBN’s primary business and cited the four-fold test as supporting evidence of an employer-employee relationship.

Procedural Developments and Administrative Rulings

• The Mediator-Arbiter issued an Order on April 14, 2010, denying AIWU’s petition for a certification election on the ground of absent employer-employee relationship.
• AIWU appealed this denial, leading to a Decision by DOLE Secretary Rosalinda Dimapilis-Baldoz on August 13, 2010.

- The DOLE Secretary reversed the Mediator-Arbiter’s Order and set aside the prior resolution. - The Secretary ordered the conduct of a certification election among the IJM workers.

Contentions on the Nature of the Employer-Employee Relationship

• The core factual dispute centered on whether the functions performed by IJM workers were integral to the ordinary business of ABS-CBN.
• Evidence presented highlighted:

- Direct hiring and payment practices by ABS-CBN. - Supervision by technical directors and issuance of company identification cards. - The consistent inclusion of IJM workers in organizational structures and benefits systems.

Issue:

• Whether the DOLE Secretary committed grave abuse of discretion in determining the existence of an employer-employee relationship between the IJM workers and ABS-CBN.
• Whether the DOLE Secretary committed grave abuse of discretion in granting the petition for a certification election filed by AIWU.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)