Title
Atlas Lithographic Services, Inc. vs. Laguesma
Case
G.R. No. 96566
Decision Date
Jan 6, 1992
A supervisory union's affiliation with a national federation representing rank-and-file employees violates Article 245 of the Labor Code, creating a conflict of interest.
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Case Digest (G.R. No. 96566)

Facts:

  1. Formation of the Union: On July 16, 1990, the supervisory, administrative, personnel, production, accounting, and confidential employees of Atlas Lithographic Services, Inc. (ALSI) affiliated with Kaisahan ng Manggagawang Pilipino (KAMPIL-KATIPUNAN), a national labor organization. The local union was named ALSI-SAPPACEA-KAMPIL (supervisors union).
  2. Petition for Certification Election: Shortly after affiliation, KAMPIL-KATIPUNAN filed a petition for certification election on behalf of the supervisors union to become the sole and exclusive bargaining agent for the supervisory employees.
  3. Opposition by ALSI: ALSI opposed the petition, arguing that under Article 245 of the Labor Code, KAMPIL-KATIPUNAN could not represent supervisory employees because it also represented the rank-and-file employees union, which would violate the principle of separation of unions.
  4. Med-Arbiter’s Decision: On September 18, 1990, the Med-Arbiter ruled in favor of KAMPIL-KATIPUNAN, ordering a certification election among the supervisory employees.
  5. Appeal and DOLE Resolution: ALSI appealed the decision, but the Department of Labor and Employment (DOLE) affirmed the Med-Arbiter’s order. ALSI’s motion for reconsideration was also denied, prompting the filing of this petition for certiorari.

Issue:

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Ruling:

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Ratio:

  1. Conflict of Interest: The Court emphasized that allowing supervisory employees to affiliate with a national federation representing rank-and-file employees would create a conflict of interest. Supervisors, who are tasked with recommending managerial actions, may act contrary to the interests of rank-and-file employees in areas such as discipline, collective bargaining, and strikes.
  2. Separation of Unions: Article 245 of the Labor Code prohibits supervisory employees from joining or assisting labor organizations of rank-and-file employees. This prohibition extends to supervisors affiliating with a national federation that includes rank-and-file unions, especially when the supervisors directly oversee those rank-and-file employees.
  3. Legislative Intent: The Court noted that the legislative intent behind Article 245 is to prevent supervisors from merging with rank-and-file employees in labor organizations, as their roles and interests are distinct. The law aims to maintain a clear separation between the two groups to avoid conflicts and ensure labor peace.
  4. Jurisprudence and Legal Basis: The Court distinguished this case from Adamson & Adamson, Inc. v. CIR, where the rank-and-file employees were not directly under the supervision of the supervisors involved. In this case, the rank-and-file employees are directly supervised by the supervisors, making the conflict of interest more pronounced.
  5. Literal vs. Equitable Interpretation: The Court rejected technicalities and emphasized the importance of interpreting the law in a way that promotes equity, justice, and labor peace. The literal construction of the law should not override its intent to prevent conflicts of interest.
  6. Employer’s Concession: The Court noted that ALSI’s decision to allow KAMPIL-KATIPUNAN to represent its supervisors did not validate the DOLE’s erroneous ruling. The Court maintained that the law must be upheld regardless of the employer’s concessions.


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