Case Digest (G.R. No. 76219)
Facts:
GTE Directories Corporation v. Hon. Augusto S. Sanchez and GTE Directories Corporation Employees Union, G.R. No. 76219, May 27, 1991, Supreme Court First Division, Narvasa, J., writing for the Court.GTE was engaged in publishing PLDT telephone directories and assigned sales territories to its Premise Sales Representatives (PSRs) using a grid system with revenue quotas. In mid-1984 GTE adopted revised sales strategies and a new Sales Evaluation and Production Policy (memorandum dated October 12, 1984), later supplemented by Sales Administrative Practices and grid deadlines in 1985. GTE required PSRs to submit individual reports reflecting target revenues by specified grid deadlines; schedules were issued and revised by memoranda of July and August 1985.
The union objected to the new policies and sought time to propose revisions. On August 6, 1985 the union filed a notice of strike alleging unfair labor practices (including refusal to bargain, open territory policy, illegal suspension of a union officer, and non-payment issues). GTE repeatedly directed PSRs to submit reports (multiple memoranda and suspension warnings). When the PSRs refused to comply, GTE suspended and ultimately terminated fourteen recalcitrant sales representatives on August 29, 1985; these included union officers. The union thereafter declared a strike (about 60 participants).
Conciliation efforts by the Bureau of Labor Relations failed and the Acting Labor Minister, citing Article 264(g) of the Labor Code, assumed jurisdiction by Order dated December 6, 1985 and directed return-to-work and hearing by the Bureau. GTE moved for reconsideration. By Resolution of January 20, 1986 (Minister Ople) the motion was denied but the order left unresolved whether the dismissed fourteen were included in the return-to-work directive. Minister Ople reiterated management prerogatives in a clarificatory order of January 21, 1986. Acting Minister Augusto Sanchez adjudicated the dispute on March 31, 1986: he ordered negotiations on the Grid Schedule and Sales Policy and directed reinstatement of the fourteen with back wages. Both parties sought reconsideration.
By Decision of June 6, 1986, Minister Sanchez reaffirmed reinstatement and back wages but remanded certain unresolved union claims to the Bureau of Labor Relations. On October 1, 1986, Sanchez denied GTE’s further motion for reconsideration, found GTE guilty of unfair labor practice for allegedly dismissing the fourteen in bad faith during conciliation, and directed management to pay striking workers str...(Subscriber-Only)
Issues:
- Did the Labor Minister properly assume jurisdiction over the dispute under Article 264(g) (or Article 263(g) as later cited) of the Labor Code by finding the dispute to be adversely affecting the national interest?
- Did the Labor Minister commit grave abuse of discretion in ordering reinstatement with back wages of the fourteen dismissed sales representatives and in finding an unfair labor practice and awarding strike-duration pay, given the facts of repeated ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)