G.R. No. 193798 - Coca-Cola Bottlers Philippines, Inc. vs. Ilocos Professional and Technical Employees Union

Coca-Cola Bottlers Philippines, Inc. (CCBPI) is a domestic corporation engaged in the beverage business, operating the Ilocos Norte Plant.
Ilocos Professional and Technical Employees Union (IPTEU) is a registered independent labor organization based at the same plant.

On July 9, 2007, IPTEU filed a verified petition for certification election to represent approximately 22 rank-and-file professional and technical employees.
CCBPI opposed, claiming that certain positions (e.g., Sales Logistics Coordinator, Maintenance Foreman) are supervisory and others (e.g., Financial Analysts, Quality Assurance Specialists) are confidential, rendering them ineligible. CCBPI also sought revocation of IPTEU’s registration for failing the 20% membership requirement.

A preliminary hearing was held on July 19, 2007; CCBPI declined voluntary recognition.
On August 23, 2007, Mediator-Arbiter Gacad-Ulep granted IPTEU’s petition, defined the bargaining unit as “all rank-and-file Exempt (Professional and Technical) Workers” not in existing units, and ordered a certification election.

CCBPI appealed to the Secretary of Labor and Employment (SOLE) on September 3, 2007, and filed a motion to suspend proceedings on September 5, 2007, but the Mediator-Arbiter continued preparation for election.
A pre-election conference was held on September 10, 2007; the election occurred on September 21, 2007, with 16 of 22 votes cast.
CCBPI filed protests and challenged the voters as supervisory/confidential. On October 22, 2007, the Mediator-Arbiter denied the challenge, canvassed the 16 votes (14 for IPTEU), and proclaimed IPTEU sole bargaining agent.
The SOLE denied CCBPI’s appeal on May 6, 2008, holding that the 22 employees were excluded from the incumbent union’s coverage, that access to business information alone does not render them confidential for labor relations, and that the election order is not appealable.
CCBPI’s petition for certiorari to the Court of Appeals (CA) was denied by Decision (March 17, 2010) and Resolution (September 16, 2010). CCBPI elevated the case to the Supreme Court via Rule 45.

Are the 22 subject employees properly classified as rank-and-file exempt workers, or are they supervisory/confidential and thus ineligible?
Was the certification election of September 21, 2007 valid despite the pending appeal and motion to suspend proceedings?
Does the existence of an incumbent bargaining agent (Ilocos Monthlies Union) preclude IPTEU’s certification?
Did the Mediator-Arbiter lose jurisdiction over the case upon the filing of appeals and motions to suspend?