Title
Caltex Refinery Employees Association vs. Brillantes
Case
G.R. No. 123782
Decision Date
Sep 16, 1997
The ruling in Caltex Refinery Employees Association v. Brillantes addressed labor disputes over a Collective Bargaining Agreement, affirming the Secretary of Labor's orders with modifications on wage increases and union benefits.
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Case Digest (G.R. No. 123782)

Facts:

  • The case involves the Caltex Refinery Employees Association (CREA) as the petitioner and Hon. Jose S. Brillantes, Acting Secretary of the Department of Labor and Employment, along with Caltex (Philippines), Inc. as respondents.
  • The existing Collective Bargaining Agreement (CBA) was set to expire on July 31, 1995.
  • CREA and Caltex engaged in negotiations for a new CBA, facilitated by the National Conciliation and Mediation Board (NCMB) and the Department of Labor and Employment (DOLE).
  • After eight meetings, several issues remained unresolved, leading CREA to declare a deadlock and file a notice of strike on July 24, 1995.
  • Conciliation meetings failed to resolve disputes, prompting a strike vote on August 16, 1995, where union members chose to walk out.
  • Caltex filed a petition for assumption of jurisdiction with DOLE, which was granted on August 22, 1995, resulting in an order to enjoin any strike or lockout.
  • Despite the order, CREA initiated a strike on August 25, 1995, which was lifted on September 9, 1995, after further conciliation meetings.
  • The Secretary of Labor issued three orders addressing various issues, including wage increases and union security clauses.
  • Dissatisfied with these orders, CREA filed a petition for certiorari under Rule 65 of the Rules of Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petition was partly meritorious.
  • The Court affirmed the Secretary's orders with the modification that the issue regarding the union security clause be rema...(Unlock)

Ratio:

  • The Court emphasized that factual findings of quasi-judicial agencies like DOLE are generally binding and entitled to great respect if supported by substantial evidence.
  • The extraordinary remedy of certiorari under Rule 65 is limited to issues of jurisdiction or grave abuse of discretion, not to re-evaluating evidence or factual findings.
  • Wage Increase: The Secretary's decision on wage increases was reasonable, considering financial capacity, inflation, and existing benefits. CREA's arguments did not convincingly demonstrate grave abuse of discretion.
  • Union Security Clause: The Secretary failed to resolve the union security clause issue, which is critical for union strength and stability, constituting grave abuse of discretion.
  • Retirement Benefits: The Secretary's decision to respec...continue reading

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