Facts:

The case involves two consolidated petitions: G.R. No. 197089 and G.R. No. 207971. The petitioner in G.R. No. 197089 is the Asian Institute of Management Faculty Association (AFA), while the respondent is the Asian Institute of Management (AIM). The case was decided by the Supreme Court on August 31, 2022. AFA, formed on October 14, 2004, received its Certificate of Registration from the Department of Labor and Employment (DOLE) on December 20, 2004, confirming its status as a legitimate labor organization. AIM opposed this registration, claiming that its faculty members were managerial employees and thus ineligible to join labor unions under Article 255 of the Labor Code.

On May 16, 2007, AFA filed a Petition for Certification Election with DOLE seeking a certification election to determine the exclusive bargaining agent for AIM’s faculty. In response, AIM filed a Petition to Cancel AFA’s Certificate of Registration on July 11, 2007, leading to the case in G.R. No. 207971. Init

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Facts:

Formation and Registration of the Asian Institute of Management Faculty Association (AFA)

• In October 2004, faculty members of the Asian Institute of Management (AIM) formally organized the AFA to represent their interests in matters affecting their rights and welfare.
• On December 20, 2004, the Department of Labor and Employment issued a Certificate of Registration to AFA, recognizing it as a legitimate labor organization.
• AIM opposed the registration on the ground that its faculty members were managerial employees, claiming they held powers such as determining faculty standards and executing administrative functions.

Organizational Structure and Faculty Roles at AIM

• The dispute centered on the nature and functions of AIM’s faculty members.
• Faculty members, although involved in administrative and advisory roles, performed their core duty of teaching.
• AIM’s Policy Manuals (both old and revised) outlined faculty responsibilities emphasizing teaching, research, and service.
• The Policy Manuals provided guidelines regarding responsibilities, work hours, and the structure of academic administration.
• Faculty powers to determine academic policies were described as “recommendatory” in nature because such recommendations required the Board of Trustees’ approval.
• Specific provisions detailed teaching sessions, load requirements, and other academic deliverables.

Proceedings and Controversies in Labor and Certification Election Cases

• Two consolidated cases were brought before the courts:
• G.R. No. 197089 involved AFA’s petition for a certification election and its challenge of the Court of Appeals’ earlier rulings regarding the eligibility of its members to engage in collective bargaining.
• G.R. No. 207971 stemmed from AIM’s petition for cancellation of AFA’s Certificate of Registration based on its assertion that AFA’s membership included managerial employees.
• Key procedural events included:
• AFA filing a Petition for Certification Election on May 16, 2007.
• AIM filing a Petition for Cancellation of Registration on July 11, 2007.
• Subsequent rulings by the Department of Labor and Employment and resolutions by the Bureau of Labor Relations and the Court of Appeals.
• Evidence and argumentation revolved around:
• The exercise of policymaking functions by faculty members.
• Whether those functions conferred managerial status.
• The proper venue and grounds for challenging the legal personality and registration of a labor union.

Evidentiary and Administrative Findings

• The administrative agencies (the Secretary of Labor and Employment and the Bureau of Labor Relations) initially held that the faculty members were not managerial employees.
• In contrast, the Court of Appeals later argued that the faculty’s participation in policy determination might qualify them as managerial.
• The dispute extended to whether the employer’s participation in certification election proceedings was permissible, with the employer (AIM) taking an adversarial stance.
• Issues pertaining to rigid work hours and independent judgment were examined in detailed comparisons with previous cases such as Engineering Equipment, Inc. and University of the Philippines v. Ferrer-Calleja.

Issue:

Determination of Employment Status

• Whether or not the faculty members of AIM are classified as managerial employees.
• How the faculty’s administrative and policy-determining roles, as outlined in the AIM Policy Manuals, align with the definition of managerial employees under the Labor Code and subsequent jurisprudence.

Legitimacy of a Labor Organization and Its Certification Election

• Whether the legitimacy of AFA as a labor organization may be collaterally attacked in proceedings for certification election.
• Whether the inclusion of employees who might be managerial (if any) should affect the conduct of the certification election.
• Whether AIM, as an employer, had the legal right to oppose the certification election by attacking the organizational status of AFA.

Grounds for Cancellation of AFA’s Registration

• Whether the allegations of misrepresentation regarding the employment status of its members (i.e., asserting they are managerial employees) justify the cancellation of AFA’s Certificate of Registration.
• Whether the exclusive grounds specified in the Labor Code for cancellation of union registration have been met.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)