Case Digest (G.R. No. 88158)
Facts:
In Asian Institute of Management Faculty Association v. Asian Institute of Management (G.R. Nos. 197089 & 207971, August 31, 2022), the Supreme Court resolved two consolidated petitions arising from the faculty of the Asian Institute of Management (AIM). In 2004, AIM’s tenure-track faculty formed the Asian Institute of Management Faculty Association (AFA) and obtained a Certificate of Registration from the Department of Labor and Employment (DOLE) recognizing it as a legitimate labor organization. AIM opposed, arguing that its faculty are managerial employees precluded by Article 255 of the Labor Code from union membership. In 2007, AFA filed a Petition for Certification Election with DOLE-NCR to determine the exclusive bargaining agent among AIM faculty, while AIM separately filed a Petition for Cancellation of AFA’s registration with the Bureau of Labor Relations. The DOLE-NCR Mediator-Arbiter denied the certification election petition, finding AFA’s members managerial; the SeCase Digest (G.R. No. 88158)
Facts:
- Formation and Registration
- In October 2004, the faculty of the Asian Institute of Management (AIM) formed the Asian Institute of Management Faculty Association (AFA).
- On December 20, 2004, the Department of Labor and Employment (DOLE) issued AFA Certificate of Registration No. NCR-UR-12-4075-2004.
- Administrative Proceedings
- AIM opposed AFA’s registration, alleging its faculty were managerial employees.
- May 16, 2007: AFA filed a Petition for Certification Election before DOLE-NCR.
- July 11, 2007: AIM filed a Petition for Cancellation of AFA’s registration.
- August 30, 2007: DOLE-NCR Medi-Arbiter denied the certification election, finding AFA’s members managerial.
- February 16, 2009: DOLE-NCR granted AIM’s cancellation petition and delisted AFA.
- December 29, 2009: Bureau of Labor Relations (BLR) reversed and reinstated AFA’s registration.
- February 20, 2009: DOLE Secretary reversed the Medi-Arbiter and ordered the certification election to proceed.
- Court of Appeals and Supreme Court Proceedings
- October 22, 2010: Court of Appeals (CA) reversed the Secretary, reinstating the denial of election.
- January 8, 2013: CA ruled in AIM’s favor in the cancellation case, affirming BLR’s reinstatement order.
- G.R. No. 197089 (AFA’s certiorari petition vs. CA decision on election) and G.R. No. 207971 (AIM’s certiorari petition vs. CA decision on cancellation) were filed and consolidated by the Supreme Court on January 23, 2017.
Issues:
- Are AIM’s faculty members “managerial employees” disqualified from unionizing?
- May the legitimacy of a labor organization be collaterally attacked in certification-election proceedings?
- Is AFA a legitimate labor organization entitled to conduct a certification election?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)