Case Digest (G.R. No. 79025) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 21, 1985, Benguet Electric Cooperative, Inc. (BENECO) received a petition from the BENECO Workers’ Labor Union–Association of Democratic Labor Organizations (BWLU-ADLO) seeking direct certification as the sole and exclusive bargaining representative of all its 214 rank-and-file employees at Alapang, La Trinidad, Benguet. BWLU-ADLO alleged that 198 employees (92.5%) supported the petition, no certification election had occurred in the last 12 months, no collective bargaining representative existed, and no collective bargaining agreement was in place. The Beneco Employees Labor Union (BELU) opposed, claiming prior certification in October 1980 and pending mediation and unfair labor practice cases before the National Labor Relations Commission. BENECO moved to dismiss, asserting its employees were also cooperative members and thus ineligible to form or join a labor organization. On September 2, 1985, the med-arbiter of the Bureau of Labor Relations (BLR) granted BWLU-ADLO’s Case Digest (G.R. No. 79025) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for Direct Certification
- On June 21, 1985, Beneco Workers’ Labor Union-ADLO (BWLU-ADLO) filed a petition for direct certification as sole and exclusive bargaining representative of all rank and file employees of Benguet Electric Cooperative, Inc. (BENECO) at La Trinidad, Benguet, alleging:
- BENECO employs 214 rank and file workers, of whom 198 (92.5%) support the petition.
- No certification election in the past 12 months; no existing bargaining representative or collective bargaining agreement.
- Opposition filed by BENECO Employees Labor Union (BELU), claiming:
- It was certified by a med-arbiter order dated October 20, 1980.
- Two pending NLRC cases on bargaining deadlock and unfair labor practice bar any representation question.
- Med-Arbiter Proceedings and Certification Election
- Med-arbiter’s September 2, 1985 order gave due course to the petition but limited voters to the 37 employees who were non-members and not owners of the cooperative. Appeals by BELU and BENECO were dismissed on March 25, 1986; BENECO’s certiorari (G.R. No. 74209) was likewise dismissed on April 28, 1986.
- On October 1, 1986 a certification election was conducted:
- BENECO protested inclusion of member-consumers, claiming only 4 non-members were eligible.
- Eighty-three votes were cast, BELU garnered 49. A formal protest by BENECO was dismissed by the med-arbiter on February 17, 1987, and affirmed by BLR Director Ferrer-Calleja on June 23, 1987, certifying BELU as the exclusive bargaining agent.
- Supreme Court Proceedings
- BENECO filed a petition for certiorari against the BLR Director’s resolution, alleging grave abuse of discretion; the Solicitor General sided with BENECO.
- On April 19, 1989, the Supreme Court gave due course to the petition and required submission of memoranda.
Issues:
- Did the BLR Director commit grave abuse of discretion in certifying BELU as the sole and exclusive bargaining representative by allowing cooperative members (co-owners) to vote in and decide the October 1, 1986 certification election?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)