G.R. No. 123782 - Caltex Refinery Employees Association vs. Brillantes

In anticipation of the expiration of the old CBA on July 31, 1995, the petitioner (Caltex Refinery Employees Association) and the private respondent (Caltex Philippines, Inc.) entered into negotiations regarding the terms and conditions of employment.
The negotiation process was assisted by the National Conciliation and Mediation Board (NCMB) and the Department of Labor and Employment (DOLE).
Although some issues were amicably settled, others remained unresolved, prompting the conduct of eight meetings, which eventually ended in a declared deadlock by the petitioner.

On July 24, 1995, following the deadlock, the petitioner filed a notice of strike.
Despite six conciliation meetings conducted by the NCMB and additional efforts at the plant level, no substantial agreement was reached, leading to the union opting for a walkout during a strike vote on August 16, 1995.
In response, the private respondent petitioned DOLE for the assumption of jurisdiction over the dispute under Article 263(g) of the Labor Code.
On August 22, 1995, DOLE, through an order by the acting secretary, assumed jurisdiction over the entire dispute and enjoined any strike or lockout.

Despite the injunction, the petitioner commenced strike action on August 25, 1995, setting up pickets at the private respondent’s premises.
DOLE Undersecretary Bienvenido Laguesma intervened by conducting additional conciliation meetings, eventually convincing the striking employees to return to work on September 9, 1995.
Following the resumption of work, the parties submitted their respective position papers concerning unresolved issues, which included not only the terms of the new CBA but also contentious matters such as the legality of the strike and the termination of union officers.

The first order, dated October 29, 1995, addressed various aspects of the new CBA, including wage increases, provisions on benefits, and continuity of certain existing company policies.
On November 21, 1995, a second order was issued denying the motions for reconsideration and clarification, thereby affirming the previous order with some modifications.
A third order, dated January 9, 1996, further denied a subsequent motion for reconsideration, while also stressing that no additional motions of the same nature would be entertained.
These orders resolved several disputed issues: wage increase rates, the union security clause, the applicability of the new versus the old retirement plan, the grievance and arbitration mechanisms, and the nature of the signing bonus.

Dissatisfied with the orders issued by the acting Secretary of Labor and Employment—particularly on the union security clause and other key issues—the petitioner filed a petition for certiorari under Rule 65.
The petitioner contended that the secretary’s orders exhibited grave abuse of discretion by largely adopting the proposals of the private respondent and by failing to resolve critical issues inherent in the collective bargaining process.

Whether the orders issued by the acting Secretary of Labor and Employment constitute grave abuse of discretion.

Was the award of wage increases at 14% (for 1995 and 1996) and 13% (for 1997) justified given the economic conditions—including actual inflation rates, financial capacity of the company, and productivity considerations?
Did the secretary err in addressing the union security clause by leaving it unresolved and merely deferring it as a procedural matter?
Was the exclusion of approximately 40 employees from the new retirement plan, despite prior opportunity to shift, an arbitrary or discriminatory practice?
Did the modifications in the grievance and arbitration machinery, as well as the adjustments to the signing bonus, reflect a fair balancing of interests or show a capricious exercise of discretion?

Whether the petition under Rule 65 is the proper remedy, given that the issues raised involve factual determinations intertwined with administrative judgment rather than pure questions of law or jurisdiction.