Case Digest (G.R. No. 127422)
Facts:
LMG Chemicals Corporation filed a petition for certiorari under Rule 65 challenging orders dated October 7, 1996 and December 16, 1996 issued by the Secretary of the Department of Labor and Employment, Hon. Leonardo A. Quisumbing, in a labor dispute with Chemical Workers Union over a new collective bargaining agreement and wage increase following a strike that began April 16, 1996 and after the Secretary assumed jurisdiction on May 20, 1996. The Secretary ordered a P140 per day wage increase to be incorporated in the CBA and directed that the new CBA retroact to January 1, 1996; the company’s motion for reconsideration was denied and the company brought the petition to the Court.
Issues:
- Did the Secretary of Labor and Employment commit grave abuse of discretion in awarding a P140 per day wage increase despite the petitioner's asserted financial losses?
- Did the Secretary of Labor and Employment commit grave abuse of discretion in ordering that the new CBA retroact to January 1, 1996?
Ruling:
The Court DENIED the petition and AFFIRMED the Secretary’s orders dated October 7, 1996 and December 16, 1996. The Court held that the Secretary did not commit grave abuse of discretion in awarding the wage increase. The Court further held that, having assumed jurisdiction in a dispute impressed with national interest, the Secretary possessed plenary discretion to determine the retroactivity of the CBA and did not abuse that discretion in ordering retroactivity to January 1, 1996.
Ratio:
The Secretary considered the parties’ evidence and reasonably based the wage award on the company’s consolidated financial condition, noting that losses in one division were offset by gains in others and that the company had earlier offered P135 per day and had granted supervisory increases; these facts negated a finding of whimsical or capricious action. Regarding retroactivity, the Secretary’s assumption of jurisdiction over a dispute affecting national interest carried plenary powers to resolve all controversies arising therefrom, including the effectivity of arbitral awards, and precedent supported such authority under Article 253-A of the Labor Code; doubts in labor-law interpretation were resolved in favor of labor.
Doctrine:
- The Secretary of Labor’s assumption of jurisdiction in disputes affecting national interest carries plenary and discretionary power to resolve all questions arising from the dispute, including retroactivity of awards.
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