Facts:

The case involves petitioners Manolito Barles, Patricio Elomina, and Juan Sayo, who were elected as president, treasurer, and auditor, respectively, of the Ilaw Buklod ng Manggagawa's IBM Local Chapter No. 15 in February 1991. Private respondents Joresty Oquendo and Juanito Ragasa contested the same positions but lost. On June 24, 1992, the new Executive Board passed a resolution to increase union dues from P16.00 to P40.00 per month, which was ratified by the members. On August 3, 1992, Oquendo and Ragasa filed a petition with the Bureau of Labor Relations (BLR) for an immediate audit of the union funds. The BLR issued an order on November 10, 1992, directing an audit, but this order was appealed to the Secretary of the Department of Labor and Employment (DOLE). The Secretary dismissed the petition on February 8, 1993, citing it as a duplication of a prior complaint. However, after a motion for reconsideration, the Secretary reinstated the audit order on April 5, 1993, b...

Facts:

1. Election of Union Officers:

   • In February 1991, petitioners Manolito Barles, Patricio Elomina, and Juan Sayo were elected as president, treasurer, and auditor, respectively, of Ilaw Buklod ng Manggagawa's IBM Local Chapter No. 15. Private respondents Joresty Oquendo and Juanito Ragasa lost in the same election.

2. Increase in Union Dues:

   • On 24 June 1992, the new Executive Board passed a resolution increasing union dues from P16.00 to P40.00 a month, which was ratified by the members.

3. Petition for Audit of Union Funds:

   • On 3 August 1992, private respondents filed a petition with the Bureau of Labor Relations (BLR) for the immediate audit and examination of union funds.

4. BLR Proceedings:

   • On 10 November 1992, the BLR ordered an audit, but this was appealed to the Office of the Secretary of Labor.
   • On 8 February 1993, the Office of the Secretary dismissed the petition, but later reconsidered and reinstated the audit order on 5 April 1993.
   • On 13 August 1993, the Office of the Secretary modified its order, endorsing the audit to the DOLE Regional Office No. IV.

5. Petitioners' Resistance to Audit:

   • Petitioners filed a petition for certiorari with the Supreme Court (G.R. No. 111671) to annul the audit order. The Supreme Court dismissed the petition on 22 November 1993 and with finality on 24 January 1994.
   • Despite notices, petitioners failed to attend pre-audit conferences, and the Regional Office proceeded with the audit based on certifications from the employer.

6. Regional Director's Order:

   • On 2 June 1994, the Regional Director issued an order requiring petitioners to explain discrepancies in union funds and open the books of accounts to members.

7. Appeal to the Secretary of Labor:

   • Petitioners appealed to the Secretary of Labor, arguing denial of due process, prescription, and violation of Article 274 of the Labor Code.
   • On 28 October 1994, the Secretary of Labor endorsed the appeal to the BLR.

8. BLR Resolutions:

   • On 14 March 1995, the BLR upheld the Regional Director's order but noted the audit was incomplete and ordered a re-audit.
   • On 25 April 1995, the BLR denied petitioners' motion to reconsider, asserting its jurisdiction over union account examinations.

Issue:

1. Whether the Bureau of Labor Relations (BLR) has jurisdiction to review decisions of the DOLE Regional Director involving the examination of union accounts, endorsed to it by the Secretary of Labor.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)