G.R. No. 204753 - United Coconut Planters Bank vs. Spouses Sy

Case Digest (G.R. No. 204753)
Expanded Legal Reasoning Model

Facts:

Parties and Corporate Structure

De Ocampo Memorial Schools, Inc. (Petitioner) is a domestic corporation organized under Philippine law, operating two main divisions:

De Ocampo Memorial Medical Center (DOMMC) – its hospital entity;
De Ocampo Memorial Colleges (DOMC) – its school entity.

Bigkis Manggagawa sa De Ocampo Memorial School, Inc. (Respondent) is a labor union which obtained its registration through a Certificate of Creation.

Union Registrations and Early Filings

On September 26, 2003, Union Registration No. NCR-UR-9-3858-2002 was issued in favor of Bigkis Manggagawa sa De Ocampo Memorial Medical Center - LAKAS (BMDOMMC).
Subsequently, on December 5, 2003, BMDOMSI was issued a Union Registration/Certificate of Creation of Local Chapter No. NCR-12-CC-002-2003, declaring it a legitimate labor organization.

Petition for Cancellation of Union Registration

On March 4, 2004, De Ocampo filed its Petition for Cancellation of Certificate of Registration with the Department of Labor and Employment – National Capital Region (DOLE-NCR).
The petition alleged:

Misrepresentation, false statement, and fraud in the union’s registration process, particularly because BMDOMSI shared the same set of officers and members with BMDOMMC.
Mixed membership composition involving both rank-and-file and managerial/supervisory employees.
An inappropriate bargaining unit as a basis for cancellation.

A Supplemental Petition was later filed on April 13, 2004 to inform DOLE-NCR of the cancellation of BMDOMMC’s Certificate of Registration, with supporting documentation from an earlier DOLE-NCR decision.

Administrative Proceedings and Initial Decisions

On July 26, 2004, Acting Regional Director Ciriaco A. Lagunzad III of DOLE-NCR ruled that BMDOMSI committed misrepresentation by depicting the bargaining unit as composed exclusively of faculty and technical employees, despite evidence showing that most union officers and many members belonged to the General Services Division.
BMDOMSI denied the allegations and asserted that the petition was aimed solely at impeding the formation of the union.
BMDOMSI then filed an appeal with the Bureau of Labor Relations (BLR).
On December 29, 2004, the BLR reversed the DOLE-NCR’s finding of misrepresentation:

It held that De Ocampo failed to prove mixed membership allegations.
It noted that the application specified that union members were rank-and-file employees under technical and faculty classifications.
It further ruled that the existence of an “inappropriate bargaining unit” did not automatically justify cancellation of union registration.

Court of Appeals Review and Subsequent Proceedings

De Ocampo then filed a Petition for Certiorari with the Court of Appeals (CA) seeking annulment of the BLR Decision and a DOLE resolution denying its motion for reconsideration.
The CA affirmed the BLR Decision:

It found no fraudulent or misrepresentative conduct in the registration process.
It acknowledged that while union members were drawn from academic, non-academic, and general services, this diversity did not establish grounds for cancellation under Article 239 (now Article 247) of the Labor Code.
It reiterated that mere lack of mutuality or commonality among members does not automatically bar the union’s existence.

A motion for reconsideration by De Ocampo was denied in the Resolution dated June 21, 2010.

Contentions Raised by De Ocampo

De Ocampo maintained that:

BMDOMSI intentionally omitted the existence of BMDOMMC during its registration, despite sharing the same set of officers and members.
The union misrepresented its composition by suggesting that BMDOMMC was a separate labor entity, thereby hiding the fact that the union’s membership lacked mutuality or common interest.

It further argued that such misrepresentations and omissions, if proven, could vitiate the members’ consent and constitute grounds for cancellation under Article 247 of the Labor Code.

Legal Framework and Final Administrative Findings

The administrative records, including those from the BLR and CA, underscored that:

BMDOMSI’s application duly indicated the composition of its bargaining unit.
There was no evidence of grave misrepresentation, fraud, or false statements that could undermine the legitimacy of the registration.

The decisions emphasized that the cancellation of union registration is limited to the specific grounds enumerated in Article 247 of the Labor Code.
Ultimately, the registration of BMDOMSI was maintained and the petition for cancellation was rejected, leading to the current petition for review.

Resolution and Final Outcome

The Supreme Court, reviewing the entire record, denied the petition for review.
It upheld the findings of the DOLE-NCR, BLR, and CA that there was no misrepresentation, fraud, or false statement in the union’s registration process.

Issues:

Whether BMDOMSI committed misrepresentation, false statement, or fraud in its union registration by:

Suppressing the existence and relevance of BMDOMMC, despite sharing the same set of officers and members.
Misrepresenting the nature of its bargaining unit by depicting it as composed solely of rank-and-file employees under specific occupational classifications.

Whether the observed lack of mutuality or commonality of interest among the union members constitutes grounds for cancellation of the registration.

Whether the administrative agencies (DOLE-NCR and BLR), and subsequently the Court of Appeals, correctly applied the relevant provisions of the Labor Code (Article 247) in finding no basis for cancellation.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 204753) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 204753) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 204753)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 204753)
Expanded Legal Reasoning Model