Title
Baptista vs. Villanueva
Case
G.R. No. 194709
Decision Date
Jul 31, 2013
Former union members expelled for filing external complaints without exhausting internal remedies; termination upheld under union security clause, no ULP found.

Case Digest (G.R. No. 101251)

Facts:

  • Parties and Background
    • Petitioners: Minette Baptista, Bannie Edsel San Miguel, and Ma. Fe Dayon, former members of the Radio Philippines Network Employees Union (RPNEU).
    • Respondents: A group of union officers and members including Rosario Villanueva, Janette Roldan, Danilo Olayvar, Onofre Estrella, Catalino Ledda, Manolo Gubangco, Gilbert Oribiana, Constancio Santiago, Ruth Bayquen, Ruby Castaneda, Alfred Landas, Jr., Roselyn Garces, Eugene Cruz, Menandro Samson, Federico Munoz, and Salvador Diwa.
    • Context: The dispute arose over actions taken within the union following internal conflicts among the members.
  • Union Dispute and Internal Grievances
    • Early Allegations:
      • On April 26, 2005, petitioners and some other union members initiated a complaint for impeachment against union president Reynato Siozon on suspicion of mismanagement.
      • Subsequent re-lodgment of the impeachment complaint targeted against all union officers and members was filed with the Department of Labor and Employment (DOLE).
    • Additional Internal Proceedings:
      • Various petitions for audit covering the period 2000 to 2004 were submitted by petitioners.
      • Two written complaints (dated May 26 and May 27, 2005) were later filed against petitioners and others, alleging violations of the union’s Constitution and By-Laws.
      • On September 19, 2005, a third complaint was filed by another group of union members against petitioners and 12 others, citing violations of Article IX, Sections 2.2 and 2.5 of the RPNEU Constitution and By-Laws.
  • Investigation and Expulsion Proceedings
    • Committee Proceedings:
      • The union’s Committee on Grievance and Investigation, led by Chairman Jeric Salinas, requested petitioners to answer the complaints and attend a hearing scheduled on October 3, 2005.
      • Petitioners denied the charges and questioned the procedure used by the Committee in its investigation.
    • Recommendation for Expulsion:
      • On November 9, 2005, the Committee recommended the expulsion of petitioners and 12 others from the union.
      • On December 21, 2005, the RPNEU Board of Directors affirmed this recommendation by adopting Board Resolution No. 018-2005.
    • Formal Notice and Subsequent Communication:
      • Petitioners received a memorandum notice on December 27, 2005, informing them of their expulsion effective December 29, 2005.
      • On January 2, 2006, petitioners wrote to the union asserting that the expulsion was an ultra vires act as the Committee failed to provide them with a chance to confront the complainants.
      • On January 24, 2006, union officers informed the company of the expulsion, which eventually led to petitions for termination based on the collective bargaining agreement (CBA).
  • Termination of Employment and ULP Complaints
    • Enforcement of the Union Security Clause:
      • On February 17, 2006, RPN HRD Manager, Lourdes Angeles, notified petitioners and the 12 others of their termination from employment effective March 20, 2006 under the union security clause of the CBA.
    • Filing of ULP Complaints:
      • Petitioners filed three separate complaints for Unfair Labor Practice (ULP) against the respondents alleging that their expulsion and termination were illegal.
      • The Labor Arbiter (LA) initially ruled in favor of petitioners on April 30, 2007, ordering the reinstatement of petitioners and holding union officers culpable for ULP under Article 249 (a) and (b) of the Labor Code.
  • Subsequent Appeals and Judicial Proceedings
    • NLRC Decision:
      • On March 31, 2008, the National Labor Relations Commission (NLRC) vacated the LA decision and dismissed the ULP complaint for lack of merit.
      • The NLRC ruled that petitioners had not exhausted internal remedies before pursuing impeachment and audit petitions and that the reinstatement order was beyond LA’s jurisdiction.
    • Court of Appeals Review:
      • The Court of Appeals (CA) in its March 9, 2010 Decision, upheld the NLRC ruling, stating that the termination under the union security clause was recognized and that petitioners were accorded due process.
      • Petitioners’ motion for reconsideration was denied in the CA’s December 1, 2010 Resolution.
    • Supreme Court Action:
      • Petitioners filed a Petition for Review on Certiorari challenging the CA decisions.
      • The Supreme Court, in its decision dated July 31, 2013, ultimately denied the petition and affirmed the decisions of the NLRC and CA.

Issues:

  • Due Process in Internal Union Proceedings
    • Whether petitioners were denied substantive and procedural due process during the internal investigation by the Committee, particularly regarding their opportunity to confront or examine the complainants.
  • Exhaustion of Internal Remedies
    • Whether petitioners should have exhausted all available internal remedies pursuant to the union’s Constitution and By-Laws prior to filing impeachment, audit petitions, and ULP complaints.
    • The proper role and application of internal grievance mechanisms in determining the legality of the expulsion from the union.
  • Allegation of Unfair Labor Practice (ULP)
    • Whether the actions of the union officers in expelling petitioners and referring the matter for termination under the union security clause constitute ULP under Articles 248, 249, and 289 of the Labor Code.
    • Whether petitioners were adequately restrained or coerced in exercise of their rights to self-organization.
  • Jurisdiction and Requisite Evidence
    • Whether the Labor Arbiter had jurisdiction to order reinstatement despite the underlying issue of expulsion, and the adequacy of evidence to support the charge of ULP.
  • Application of the Union’s Constitution and By-Laws
    • Whether the expulsion procedures adopted by RPNEU, based on its Constitution and By-Laws, were duly observed and whether they conformed to constitutional and legal standards on due process.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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