Case Digest (G.R. No. 108855) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Metrolab Industries, Inc. (petitioner) filed a Rule 65 certiorari petition challenging two resolutions of Acting Secretary of Labor and Employment Ma. Nieves Roldan Confesor dated April 14, 1992 and January 25, 1993. The respondent Union, Metro Drug Corporation Employees Association–Federation of Free Workers, represented Metrolab’s rank-and-file employees. The parties’ 1988–1990 Collective Bargaining Agreement (CBA) expired on December 31, 1990 and negotiations reached a deadlock. On August 23, 1991, the Union served a strike notice. After failed conciliation, Secretary Ruben D. Torres assumed jurisdiction under Article 263(g) of the Labor Code by order of September 20, 1991 and on December 27, 1991 resolved all disputed CBA items, directing execution of a new CBA. While a motion for reconsideration was pending, Metrolab laid off 94 employees on January 27, 1992. The Union sought a cease-and-desist order, alleging violation of the injunction against exacerbating the dispute and Case Digest (G.R. No. 108855) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Metrolab Industries, Inc. (MII) – petitioner and employer; Metro Drug Corporation Employees Association-Federation of Free Workers (Union) – respondent labor organization.
- Collective Bargaining Agreement (CBA) expired on December 31, 1990; negotiations deadlocked; Union filed strike notice on August 23, 1991.
- Assumption Orders and Layoffs
- Secretary Torres assumed jurisdiction under Art. 263(g) on September 20, 1991, enjoining strikes or lockouts; on December 27, 1991, resolved disputed CBA items and directed execution of new CBA.
- On January 27, 1992, MII laid off 94 rank-and-file employees; Union moved to enjoin, alleging violation of injunction and 30-day notice requirement.
- Administrative Proceedings and Resolutions
- Acting Secretary Confesor’s April 14, 1992 resolution declared the 94 layoffs illegal, ordered reinstatement with full backwages and incorporation of prior directives into CBA.
- MII filed partial motions; parties entered a new CBA on June 29, 1992; second layoff of 73 employees occurred on October 2, 1992; January 25, 1993 Omnibus Resolution denied MII’s motions and referred legality of second layoff to NLRC, lifting injunctions.
- Supreme Court Petition
- MII filed a petition for certiorari (Rule 65), challenging the two Secretary of Labor resolutions dated April 14, 1992 and January 25, 1993 for grave abuse of discretion and excess of jurisdiction.
- Assigned errors: (A) illegality of first layoff and ordered backwages; (B) inclusion of executive secretaries in the bargaining unit.
Issues:
- Whether the Secretary of Labor gravely abused discretion or exceeded jurisdiction in declaring the January 27, 1992 layoff of 94 employees illegal and ordering reinstatement with backwages.
- Whether the Secretary gravely abused discretion in including executive secretaries as part of the rank-and-file bargaining unit under the CBA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)