Facts:

The case involves Asia Brewery, Inc. (ABI) as the petitioner and Tunay Na Pagkakaisa ng mga Manggagawa sa Asia (TPMA) as the respondent. The dispute arose from failed negotiations for a new collective bargaining agreement (CBA) for the years 2003-2006 after the previous CBA expired in July 2003. ABI, a company engaged in the manufacture and distribution of beverages, employs approximately 1,500 workers and has distributorship agreements with at least 13 companies. After 18 negotiation sessions, the parties could not reconcile their differences, particularly regarding wages and economic benefits, leading TPMA to declare a deadlock on October 21, 2003. Subsequently, on October 27, 2003, TPMA filed a notice of strike with the National Conciliation and Mediation Board (NCMB). Despite attempts at mediation, no agreement was reached, prompting TPMA to conduct a strike vote on November 18, 2003, where 768 out of 840 members voted in favor of a strike. On November 20, 2003, ABI petit...

Facts:

Parties and Nature of the Dispute

• Petitioner: Asia Brewery, Inc. – a company engaged in the manufacture, sale, and distribution of beer, shandy, glass, and bottled water products, employing about 1,500 workers with established distributorship agreements.
• Respondent: Tunay Na Pagkakaisa ng mga Manggagawa sa Asia (TPMA) – a duly certified labor organization representing all regular rank-and-file employees of Asia Brewery, Inc.

Background and Negotiation History

• Collective Bargaining Agreement (CBA) Negotiation
• The parties had been negotiating a new CBA for the period 2003–2006 after the old CBA expired in July 2003.
• After approximately 18 negotiation sessions, the parties failed to reconcile differences, particularly on wage-related and other economic issues.
• Deadlock and Strike Preparations
• On October 21, 2003, the union declared a deadlock in negotiations.
• On October 27, 2003, TPMA filed a notice of strike with the National Conciliation and Mediation Board (NCMB), initiating formal protest measures.
• A strike vote on November 18, 2003, saw 768 of the 840 union members voting in favor of striking.

Intervention of the Department of Labor and Employment (DOLE)

• Petition for Jurisdiction
• On November 20, 2003, Asia Brewery, Inc. petitioned the Secretary of Labor to assume jurisdiction over the dispute, invoking Article 263(g) of the Labor Code.
• The union opposed such assumption, arguing that the company’s business was not indispensable to the national interest.
• Issuance of the Assumption Order
• On December 19, 2003, the public respondent, through Undersecretary/Acting Secretary Manuel G. Imson, issued an order assuming jurisdiction over the labor dispute.
• The order enjoined any strike or lockout, required both parties to submit detailed position papers (including audited financial statements from the company, CBA history, and wage details), and set a strict timeframe for compliance.

Arbitral Awards and Subsequent Motions

• Initial Arbitral Awards – Issued on January 19, 2004 by Secretary of Labor Patricia Sto. Tomas
• Wage increases were awarded on a phased basis for three years: First Year – P18.00, Second Year – P15.00, Third Year – P12.00 (totaling P45.00).
• Health care benefits were provided, including a premium payment arrangement: P1,300.00 for each covered employee and P1,800.00 for union member dependents.
• Motion for Reconsideration and Certiorari
• Respondent union and petitioning corporation each filed respective motions questioning the evidentiary basis and the discretionary exercise of the Secretary of Labor.
• On January 29, 2004, the Secretary resolved the motions through a clarificatory resolution.
• Execution of the Collective Bargaining Agreement
• On February 9, 2004, the parties executed the CBA covering August 1, 2003, to July 31, 2006.
• CA Proceedings
• On October 6, 2005, the Court of Appeals (CA) rendered its Decision affirming—with modifications—the arbitral awards.
• Key modifications included the adjustment of the CBA’s effective date, remanding the computation of wage increases (due to reliance on unaudited financial statements), and modifying the health benefit premium payment.
• Further Amended Decision
• On February 17, 2006, the CA issued an Amended Decision that partly granted and partially denied the reconsideration motions, deleting the signing bonus and remanding wage computation for further determination using externally audited financial statements.

Issue:

Authority and Representation

• Whether the Court of Appeals erred in not dismissing CA-G.R. SP No. 83168 despite allegations that the individual (Rodrigo Perez) who filed the petition lacked proper authority to represent the union.
• Whether the alleged procedural defects in the union’s internal resolution affected the validity of Perez’s authority.

Evidentiary Basis for Wage Determination

• Whether the CA erred in remanding the wage increase issue to the Secretary of Labor on the ground that Asia Brewery, Inc. submitted unaudited financial statements which lack probative value and failed to comply with the Secretary’s order requiring complete audited financial statements.

Award on Health Benefits

• Whether the CA erred in awarding P1,390.00 as the premium payment for each covered employee, against petitioner’s contention that the final offer had been only P1,300.00.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)