Case Digest (G.R. No. 102084) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves De La Salle University Medical Center and College of Medicine (DLSUMCCM) as the petitioner and various respondents, including Hon. Bienvenido E. Laguesma, Undersecretary of Labor and Employment, and Rolando S. De La Cruz, Med-Arbiter from the Department of Labor and Employment, as well as the De La Salle University Medical Center and College of Medicine Supervisory Union-Federation of Free Workers (FFW-DLSUMCCMSUC). DLSUMCCM is located in Dasmariñas, Cavite and serves both as a hospital and a medical school. On April 17, 1991, the Federation of Free Workers issued a certificate recognizing FFW-DLSUMCCMSUC as a local chapter. On the same day, the FFW filed a petition for a certification election among DLSUMCCM's supervisory employees, which DLSUMCCM opposed. The objection was based on claims that many employees who signed the petition were managerial staff and that the union comprised both supervisory and rank-and-file personnel. Private respondent FFW-DLSUMCCMS Case Digest (G.R. No. 102084) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
De La Salle University Medical Center and College of Medicine (DLSUMCCM) is a hospital and medical school employing both managerial and supervisory staff. A labor organization composed of its supervisory employees—affiliated with the national Federation of Free Workers (FFW) and recognized by a charter certificate issued by FFW—filed a petition for a certification election among the supervisory employees. The petitioner (DLSUMCCM) contested the petition on the ground that several employees who signed were either managerial employees or were mixed in a union that also encompassed rank-and-file employees. In its reply, the supervisory union maintained that it was composed exclusively of supervisory employees and that its affiliation with FFW did not imply merger with the rank-and-file employees’ union. The med-arbiter of the Department of Labor and Employment Regional Office No. IV, after noting that the petitioner had failed to submit job descriptions to clearly distinguish managerial from supervisory employees, granted the petition for certification election. An appeal by DLSUMCCM to the Undersecretary of Labor and Employment was dismissed, with the Undersecretary ruling that the supervisory employees retained the right to self-organization separately from the rank-and-file employees—even if both were affiliated with the same national federation. DLSUMCCM then sought certiorari challenging the administrative decision, alleging abuse of discretion in allowing certification election for the supervisory union, contending that its affiliation with FFW (also representing the rank-and-file) violated Article 245 of the Labor Code.Issues:
- Whether unions formed independently by supervisory employees and rank-and-file employees of the same company may validly affiliate with the same national federation, despite the purported risk of merging the two distinct bargaining units.
- Whether the supervisor union’s affiliation with the Federation of Free Workers, which also represents the rank-and-file employees, violates the express provisions of Article 245 of the Labor Code, thereby justifying the petitioner’s opposition to a certification election.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)