Case Digest (G.R. No. 81883)
Facts:
Knitjoy Manufacturing, Inc. v. Pura Ferrer‑Calleja et al., G.R. Nos. 81883 and 82111, September 23, 1992, Supreme Court Third Division, Davide, Jr., J., writing for the Court.Petitioner in G.R. No. 81883 is Knitjoy Manufacturing, Inc. (KNITJOY); petitioners in G.R. No. 82111 include the Confederation of Filipino Workers (CFW). The respondents include Pura Ferrer‑Calleja, Director of the Bureau of Labor Relations (BLR), and the Knitjoy Monthly Employees Union (KMEU); the Knitjoy Monthly Employees Association and Confederation of Citizens Labor Unions (KMEA‑CCLU) and CFW also figure as intervenors in the administrative proceedings.
Historically, KNITJOY had a collective bargaining agreement (CBA) with the Federation of Filipino Workers (FFW) covering only regular rank‑and‑file employees paid on a daily or piece‑rate basis; regular monthly‑paid rank‑and‑file employees were not included. The CBA expired on June 15, 1987. Prior to expiration the FFW split; one faction became the CFW, which, after a certification election conducted on June 10, 1987 (initiated by TUPAS), was certified as bargaining representative for the daily/piece‑rate rank‑and‑file workers and then began negotiating a new CBA with KNITJOY.
On June 24, 1987, KMEU filed with DOLE Regional Office No. IV a petition (R‑04‑OD‑M‑6‑75‑87) for a certification election among KNITJOY’s regular rank‑and‑file monthly‑paid employees. Med‑Arbiter Rolando S. de la Cruz dismissed that petition on September 4, 1987 and instructed the parties to work toward a single union. KMEU’s motion for reconsideration was treated by the BLR as an appeal.
On December 1, 1987, BLR Director Pura Ferrer‑Calleja reversed the med‑arbiter and ordered a certification election among the monthly‑paid regular rank‑and‑file employees (excluding managerial employees), allowing choices of (1) Knitjoy Monthly Employees Union (KMEU) and (2) No Union, with the company’s latest payroll as basis for eligible voters. KNITJOY and CFW moved for reconsideration, asserting that a newly negotiated CBA (they said concluded November 27, 1987; respondents said December 12, 1987) included monthly‑paid rank‑and‑file employees within the bargaining unit and thus mooted the representation petition.
In a February 8, 1988 decision the BLR Director denied reconsideration, finding that (a) KMEU was not a party to and did not participate in ratifying the new CBA, (b) the representation petition had been pending before the CBA’s execution, and (c) the one company‑one union policy has exceptions and must yield to employees’ constitutional right to se...(Pro-only)
Issues:
- May KNITJOY’s regular rank‑and‑file monthly‑paid employees constitute an appropriate bargaining unit separate and distinct from the existing unit of daily or piece‑rate paid rank‑and‑file employees?
- Does the inclusion of monthly‑paid rank‑and‑file employees within the coverage of the new CBA between KNITJOY and CFW bar the holding of a certification election among...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)