Case Digest (G.R. No. 91902) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manila Electric Company v. Secretary of Labor and Employment (274 Phil. 549, G.R. No. 91902, May 20, 1991, En Banc), MERALCO petitioned for review of the Secretary’s November 3, 1989 Resolution affirming a Med-Arbiter’s order to hold a certification election among certain employees. On November 22, 1988, the Staff and Technical Employees Association of MERALCO (STEAM-PCWF) sought to represent (a) non-managerial employees in Pay Grades VII and above, (b) Patrol Division and Treasury Security Services personnel, and (c) employees automatically disqualified from union membership under the existing Meralco Employees and Workers Association (MEWA) collective bargaining agreement (CBA). MERALCO moved to dismiss on grounds that the petition improperly encompassed managerial staff, security guards, secretaries lacking written consent, and employees already covered by MEWA’s valid CBA, and argued it would disrupt the existing agreement and lacked the requisite 20% employee support. Th Case Digest (G.R. No. 91902) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for Certification Election
- On November 22, 1988, the Staff and Technical Employees Association of MERALCO (STEAM-PCWF) filed a petition to represent:
- Non-managerial employees with Pay Grades VII and above
- Non-managerial employees in the Patrol Division, Treasury Security Services Section, and Secretaries
- Rank-and-file employees automatically disqualified from MEWA membership
- The petition challenged exclusions under Article I, Sections 2–3 of the existing MEWA CBA for Pay Grades I–VI.
- Proceedings Before the Med-Arbiter
- MERALCO moved to dismiss on grounds that the claimed employees were managerial, security, secretarial, or already covered by MEWA, and that the petition lacked 20% written support.
- On March 15, 1989, Med-Arbiter Parungo ruled excluded employees (except managerial) could form their own union and ordered a certification election.
- Appeals and Secretary of Labor Resolution
- MERALCO appealed; MEWA intervened contending violations of Articles 232 and 245 of the Labor Code and improper bargaining unit. STEAM-PCWF opposed.
- FLAMES filed a separate petition on September 13, 1989, to represent Pay Grades VII–XIV; cases were consolidated.
- On November 3, 1989, Secretary Drilon affirmed with modification:
- Employees under MEWA-CBA Section 3 remain in existing rank-and-file unit but may choose union membership
- Included FLAMES as an election choice
- MERALCO’s motion for reconsideration was denied January 16, 1990.
- MERALCO filed a petition for certiorari with the Supreme Court on February 9, 1990; a TRO was issued February 26, 1990.
- Legislative and Organizational Developments
- RA 6715 (effective March 21, 1989) redefined managerial, supervisory, and rank-and-file employees.
- STEAM-PCWF renounced representation of Patrol/Treasury and Pay Grades I–VI; FLAMES limited to supervisory Pay Grades VII–XIV.
- MERALCO acknowledged Grades VII and above as supervisory under RA 6715 definitions.
Issues:
- Whether a separate rank-and-file bargaining unit may be established distinct from the existing MEWA unit.
- Whether Pay Grades VII and above are rank-and-file employees eligible for R&F union representation.
- Whether security guards may be included in a rank-and-file or supervisory union.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)