G.R. No. 166414 - Enrile vs. Manalastas

Interphil Laboratories Employees Union-FFW is the sole and exclusive bargaining agent of the rank-and-file employees of Interphil Laboratories, Inc., a manufacturer and packager of pharmaceutical products.
The collective bargaining agreement (CBA) between the parties was effective from August 1, 1990, to July 31, 1993.

Prior to the expiration of the CBA, union officials—including the president, Nestor Ocampo, and director Hernando Clemente—approached the company’s Vice-President for Human Resources, Allesandro G. Salazar.
In February and March 1993, the union inquired about the future duration and effectivity of the CBA, to which Salazar replied that formal negotiations would be held soon.
On April 15, 1993, during a scheduled meeting, union officers proposed a new CBA effective from August 1, 1993, with a two-year term; Salazar maintained that it was premature to decide.

On April 16, 1993, following the indecision during the meeting, all rank-and-file employees refused to adhere to their regular two-shift work schedule (6:00 a.m.–6:00 p.m. and 6:00 p.m.–6:00 a.m.).
Employees disrupted operations by halting work before completing essential tasks such as sealing containers and securing raw materials.
In response, Salazar requested another meeting with union officers, during which union director Enrico Gonzales stated that normal work would resume only if management agreed to their demands regarding the CBA.

The overtime boycott continued, and the employees collectively initiated a work slowdown campaign resulting in production delays.
On May 14, 1993, the union submitted its CBA proposal, and the company filed its counter-proposal.
On September 3, 1993, the company filed a petition with the National Labor Relations Commission (NLRC) to declare the union’s actions an illegal strike.
Later developments included:

An urgent request for preventive mediation filed on October 22, 1993, with the National Conciliation and Mediation Board (NCMB).
A petition for the assumption of jurisdiction filed by the company on November 15, 1993, with the Office of the Secretary of Labor and Employment.
The union filing a Notice of Strike on January 24, 1994, citing unfair labor practices by the company, and the subsequent staging of a strike on February 12, 1994.

On February 14, 1994, Secretary of Labor Nieves Confesor issued an assumption order directing the parties to resume work under specified conditions, including reinstatement of employees and payment of due benefits.
Meanwhile, the illegal strike case proceeded before Labor Arbiter Manuel R. Caday.
On March 16, 1994, the union moved to consolidate this case with the labor dispute pending before the Secretary.
Acting Labor Secretary Jose S. Brillantes later ordered that a formal hearing be conducted, leading to a report and recommendation submitted by Caday on September 5, 1995.
On August 13, 1997, then Secretary of Labor Leonardo A. Quisumbing adopted Caday’s recommendation, resolving the case by:

Declaring the overtime boycott and work slowdown as an illegal strike;
Declaring certain union officers to have lost their employment status; and
Finding the union’s actions to be unfair labor practices under the existing CBA.

The union contested the decision by filing a petition for certiorari in the Court of Appeals, which dismissed the petition on December 29, 1999.
The union raised several allegations in its petition before the Supreme Court, including:

Abuse of discretion for allegedly misapplying the parol evidence rule in evaluating evidence contrary to the written CBA on work schedules.
An assertion that the extension of separation benefits to union officers by the company amounted to condonation of their misconduct.
A claim that the Secretary of Labor did not have jurisdiction over the case because the petition was initially filed before the Labor Arbiter.

Whether the Secretary of Labor had proper jurisdiction and authority to rule on the illegal strike case given that the petition was previously filed before a Labor Arbiter.
Whether the subsequent involvement and participation of the union in the mandatory proceedings confirmed the Secretary’s jurisdiction.

Whether the Court of Appeals and the Labor Arbiter abused their discretion in evaluating evidence, particularly regarding the application (or alleged misapplication) of the parol evidence rule in the context of the CBA provisions on working hours.

Whether the extension of separation benefits to union officers during the pendency of the case by the respondent company constituted condonation or approval of their alleged misconduct during the illegal strike.