Title
Bautista vs. Court of Appeals
Case
G.R. No. 123375
Decision Date
Feb 28, 2005
Intra-union dispute over KKMK-MWSS officer elections; BLR jurisdiction upheld, RTC overruled; Supreme Court affirmed BLR authority under Labor Code and EO 180.
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Case Digest (G.R. No. 123375)

Facts:

Background of the Case

The case involves an intra-union dispute within the Kaisahan at Kapatiran ng mga Manggagawa at Kawani sa Metropolitan Waterworks and Sewerage System (KKMK-MWSS), a labor union in the public sector. The dispute arose from a petition filed by Bonifacio De Guzman, a former auditor of KKMK-MWSS, seeking the election of new union officers. The Bureau of Labor Relations (BLR) granted the petition and ordered the conduct of an election supervised by the Labor Organizations Division.

Incumbent Officers' Resistance

The incumbent officers of KKMK-MWSS, led by President Genaro Bautista, filed a Motion for Reconsideration with the BLR, which was denied. They then appealed to the Office of the Secretary of Labor and Employment, arguing that the BLR had no jurisdiction over intra-union disputes in the public sector. The appeal was dismissed for lack of jurisdiction, as the dispute was deemed an intra-union conflict under Executive Order No. 180.

Legal Proceedings

  1. Special Civil Action for Certiorari: Bautista and the incumbent officers filed a special civil action for certiorari with the Supreme Court, which was dismissed for being insufficient in form and substance.
  2. Petition for Prohibition: Bautista filed a petition for prohibition with the Regional Trial Court (RTC) to stop the election, and a temporary restraining order (TRO) was issued. Despite the TRO, the election proceeded on December 2, 1993.
  3. Writ of Preliminary Injunction: The RTC issued a writ of preliminary injunction to prevent the recognition of the newly elected officers. The case was later dismissed by the RTC, but the writ was reinstated upon motion for reconsideration.
  4. Court of Appeals Decision: The Court of Appeals ruled in favor of the private respondents, holding that the BLR had jurisdiction over the intra-union dispute and setting aside the RTC's orders.

Subsequent Motions and Appeals

Bautista filed a petition for review with the Supreme Court, challenging the Court of Appeals' decision. Meanwhile, a mandamus case was filed in the RTC to compel the MWSS to recognize Bautista and his group as the legitimate officers of KKMK-MWSS. A temporary restraining order was issued by the Supreme Court to halt the mandamus proceedings.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of the BLR: Article 226 of the Labor Code grants the BLR original and exclusive authority to act on all inter-union and intra-union conflicts. The election of officers within a labor union is an intra-union conflict, squarely within the BLR's jurisdiction.
  2. Applicability of Executive Order No. 180: Section 16 of Executive Order No. 180 mandates that labor laws and procedures shall be followed in resolving disputes involving government employees. This includes the BLR's authority to supervise elections and resolve intra-union disputes.
  3. Estoppel: The Court found that Bautista and his group participated in the election, as evidenced by the votes cast in his favor and the list of candidates submitted to the BLR. Therefore, the principle of estoppel applies, and they cannot now challenge the BLR's jurisdiction.
  4. Finality of the Court of Appeals' Decision: The Court upheld the Court of Appeals' decision, emphasizing that the BLR's jurisdiction over intra-union disputes is clear under the law.

Conclusion:

The Supreme Court denied Bautista's petition, affirmed the Court of Appeals' decision, and made the temporary restraining order permanent. The BLR's jurisdiction over intra-union disputes in the public sector was upheld, and the RTC was found to lack jurisdiction over such matters.


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