Case Digest (G.R. No. 141471) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Colegio de San Juan de Letran vs. Association of Employees and Faculty of Letran and Eleonor Ambas (G.R. No. 141471, September 18, 2000), the petitioner, Colegio de San Juan de Letran, and the respondent union, AEFL, began renegotiation of their 1989–1994 Collective Bargaining Agreement (CBA) in December 1992. After a referendum rejected the parties’ proposed CBA, the petitioner accused union officers of bad-faith bargaining before the NLRC; the Labor Arbiter ruled for petitioner, but the NLRC reversed. In January 1996, the union filed a strike notice citing petitioner’s non-compliance with an NLRC order and refusal to bargain. On February 7, 1996, the union submitted CBA proposals, which petitioner forwarded to its Board of Trustees only on February 13. Two days later, union president Eleonor Ambas was informed of a unilateral change in her work schedule; her grievance request was denied. Frustrated by petitioner’s inaction, the union amended its strike notice on March 13. A Case Digest (G.R. No. 141471) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Renegotiation of the Collective Bargaining Agreement (CBA)
- December 1992: Salvador Abtria, then‐union president of AEFL, initiated renegotiation of the CBA covering 1989–1994.
- Late 1992: Union elected Eleonor Ambas as president; petitioner asserted that the CBA was ready for signing and submitted it to a membership referendum, which rejected the draft.
- Administrative and judicial proceedings
- Petitioner accused the union officers of bargaining in bad faith before the NLRC; Labor Arbiter ruled for petitioner, but the NLRC reversed.
- January 1996: The union served a notice to strike alleging petitioner’s noncompliance with an NLRC order (to drop the union’s counsel) and refusal to bargain.
- New negotiation attempts and alleged delaying tactics
- January 18, 1996: Parties agreed to set aside the unsigned CBA and commence negotiations for a new 1994–1999 CBA.
- February 7, 1996: Union submitted proposals; petitioner delayed response beyond the ten‐day period under Art. 250 of the Labor Code.
- February 15, 1996: Petitioner unilaterally changed Ambas’s work schedule; her request to invoke the grievance machinery was denied.
- Strike, dismissal, and resumption of talks
- March 13, 1996: Union filed another strike notice. March 27: Ground‐rules meeting before NCMB; March 29: Petitioner dismissed Ambas for alleged insubordination; union amended strike notice.
- April 20, 1996: Further ground‐rules meeting; petitioner suspended negotiations upon news of a rival union’s certification petition.
- June 18, 1996: Union strike commenced; July 2: Secretary of Labor ordered return to work and reinstatement of strikers except Ambas. Parties filed pleadings.
- Unfair labor practice findings and appellate review
- December 2, 1996: Secretary of Labor found petitioner guilty of two counts of unfair labor practice and ordered Ambas’s reinstatement with backwages; May 29, 1997: Motion for reconsideration denied.
- August 9, 1999: Court of Appeals dismissed petitioner’s certiorari petition and affirmed the Secretary’s order.
Issues:
- Whether petitioner committed an unfair labor practice by suspending bargaining upon learning of a rival union’s certification petition.
- Whether the dismissal of union president Eleonor Ambas unlawfully interfered with employees’ right to self‐organization.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)