Case Digest (G.R. No. 210773) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In GSIS Family Bank Employees Union v. Sec. Cesar L. Villanueva, et al. (G.R. No. 210773, January 23, 2019; decision promulgated December 23, 2019), the GSIS Family Bank Employees Union, represented by its President Judith Jocelyn Martinez, petitioned the Supreme Court via Rule 65 for Certiorari, Prohibition, and Mandamus to declare GSIS Family Bank outside the coverage of Republic Act No. 10149 (the GOCC Governance Act of 2011) and compel it to negotiate a new collective bargaining agreement (CBA). The bank’s origin dates to 1969 as Royal Savings Bank, later renamed Comsavings Bank, and eventually GSIS Family Bank in 2001, with the Government Service Insurance System (GSIS) acquiring a 99.55% share by 1993. In 2010, President Aquino issued E.O. No. 7 placing a moratorium on GOCC salary increases, and in 2011 he signed R.A. 10149, creating the Governance Commission for GOCCs (GCG) to formulate a Compensation and Position Classification System (CPCS) for all GOCCs. Upon the union Case Digest (G.R. No. 210773) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Organizational Evolution
- On July 22, 1969, Royal Savings Bank incorporated as a thrift bank; placed under Central Bank receivership in July 1984.
- September 7, 1984: Memorandum of Agreement with Commercial Bank of Manila (a GSIS subsidiary) to rehabilitate and rename it Comsavings Bank.
- December 1987–July 2001: GSIS transferred holdings; Comsavings Bank became GSIS Family Bank.
- Classification and Regulatory Framework
- May 25, 2004: BSP General Counsel opined GSIS Family Bank was not a government bank under special‐charter definitions.
- September 8, 2010: EO No. 7 imposed salary/benefits moratorium on GOCCs; June 6, 2011: RA 10149 (GOCC Governance Act) created the Governance Commission.
- January–March 2013: GSIS Family Bank sought Governance Commission’s opinion; advised it lacked authority to negotiate economic terms of CBAs and that right to strike was not guaranteed.
- Labor Disputes and Judicial Proceedings
- December 20, 2013: GSIS Union demanded Christmas bonus per existing CBA; bank refused citing RA 10149 coverage.
- GSIS Union filed labor complaints, Notice of Strike, and Petition for Certiorari, Prohibition, and Mandamus before the Supreme Court (January 30, 2014), alleging GSIS Family Bank was a private bank not covered by RA 10149.
- Respondents filed Comments contesting remedy, impleading parties, and affirming bank’s status as a GOCC; BSP receiver placed GSIS Family Bank under receivership on May 13, 2016.
Issues:
- Whether a Petition for Certiorari under Rule 65 was the correct remedy against advisory opinions of the Governance Commission.
- Whether the closure of GSIS Family Bank rendered the Petition moot.
- Whether a non-chartered GOCC (GSIS Family Bank) may negotiate economic terms of a collective bargaining agreement with its employees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)