G.R. No. 210308 - Asian International Manpower Services, Inc. vs. Department of Labor and Employment

De La Salle University Medical Center and College of Medicine (DLSUMCCM) — petitioner; a hospital and medical school at Dasmariñas, Cavite.
Federation of Free Workers - De La Salle University Medical Center and College of Medicine Supervisory Union Chapter (FFW-DLSUMCCMSUC) — private respondent; a labor organization composed of supervisory employees of petitioner.
Federation of Free Workers (FFW) — national federation which issued a certificate recognizing the private respondent as a local chapter on April 17, 1991.
Respondent public officials — Hon. Bienvenido E. Laguesma, Undersecretary of Labor and Employment; Rolando S. de la Cruz, med-arbiter, DOLE Regional Office No. IV.

On April 17, 1991, FFW filed a petition for certification election on behalf of FFW-DLSUMCCMSUC among supervisory employees of DLSUMCCM.
DLSUMCCM opposed the petition, alleging that some signees were managerial employees and that the local union comprised both supervisory and rank-and-file employees.
In its May 22, 1991 reply, FFW-DLSUMCCMSUC denied the allegations and stated it sought certification only for supervisory employees and claimed separate local unions for supervisory and rank-and-file employees, each with separate charters.

On July 5, 1991, med-arbiter Rolando S. de la Cruz ordered a certification election, finding no basis to determine managerial status in the absence of job descriptions and concluding supervisory employees existed who could form a union.
The med-arbiter relied on Article 257 of the Labor Code to mandate an election and held that affiliation of separate locals with the same federation did not, by itself, violate Article 245 of the Labor Code.
On July 30, 1991, DLSUMCCM appealed to the Secret...(Subscriber-Only)

Whether respondent Laguesma gravely abused his discretion in denying DLSUMCCM's appeal and ordering a certification election among supervisory employees.
Whether unions formed independently by supervisory and rank-and-file employees of the same company may validly affiliate with the same national federation without violating Article 245 of the Labor Code.

Whether the supervisory employees who composed FFW-DLSUMCCMSUC had direct authority over the rank-and-file employees composing the othe...(Subscriber-Only)