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
Case Digest (G.R. No. 123782)
Facts:
The case involves the Caltex Refinery Employees Association (CREA) as the petitioner and the Hon. Jose S. Brillantes, in his capacity as Acting Secretary of the Department of Labor and Employment, along with Caltex (Philippines), Inc. as respondents. The events leading to the case began with the impending expiration of the existing Collective Bargaining Agreement (CBA) on July 31, 1995. Anticipating this, CREA and Caltex engaged in negotiations for a new CBA, facilitated by the National Conciliation and Mediation Board (NCMB) and the Office of the Secretary of Labor and Employment. While some terms were agreed upon, several issues remained unresolved after eight meetings, leading CREA to declare a deadlock and file a notice of strike on July 24, 1995.
Subsequent conciliation meetings failed to resolve the disputes, prompting a strike vote on August 16, 1995, where union members opted for a walkout. In response, Caltex filed a petition for assumption of jurisdiction with the Department of Labor and Employment (DOLE), which was granted on August 22, 1995. The DOLE issued an order enjoining any strike or lockout and directed both parties to submit position papers within ten days. Despite this order, CREA initiated a strike on August 25, 1995. After several conciliation meetings led by DOLE Undersecretary Bienvenido Laguesma, the strike was lifted on September 9, 1995, and the parties submitted their position papers.
The Secretary of Labor issued three orders resolving the deadlock on October 9, 1995, November 21, 1995, and January 9, 1996, addressing various issues including wage increases, union security clauses, retirement benefits, grievance machinery, and signing bonuses. Dissatisfied with these orders, CREA sought a reversal or modification through a petition for certiorari under Rule 65 of the Rules of Court.
Issue:
- Did the Secretary of Labor and Employment commit grave a...