Case Digest (G.R. No. 108855)
Facts:
Metrolab Industries, Inc. v. Hon. Ma. Nieves Roldan Confesor, G.R. No. 108855, February 28, 1996, Supreme Court First Division, Kapunan, J., writing for the Court.Petitioner Metrolab Industries, Inc. (MII) and respondent Metro Drug Corporation Employees Association–Federation of Free Workers (the Union) were parties to a Collective Bargaining Agreement (CBA) that expired on 31 December 1990; bargaining for a new CBA reached a deadlock and the Union filed a notice of strike on 23 August 1991. Conciliation efforts by the National Conciliation and Mediation Board failed.
On 20 September 1991, then Labor Secretary Ruben D. Torres issued an assumption order pursuant to Article 263(g) of the Labor Code, assuming jurisdiction over the dispute and enjoining strikes or lockouts; on 27 December 1991 he issued an order resolving disputed CBA items and directed execution of a new CBA. While a motion for reconsideration was pending, MII laid off 94 rank-and-file employees on 27 January 1992; the Union filed a motion for a cease-and-desist order alleging violation of the assumption order. MII asserted the layoff was temporary and an exercise of management prerogative; it later recalled some employees on a temporary basis.
Acting Labor Secretary Nieves Confesor, on 14 April 1992, declared the layoff of 94 employees illegal for failure to comply with the injunction against acts that might exacerbate the dispute and for noncompliance with the 30-day notice requirement, ordering reinstatement with full backwages. MII filed motions for partial reconsideration and clarification; after further bargaining the parties signed a new CBA on 29 June 1992 without prejudice to pending motions. MII implemented a second layoff of 73 employees on 2 October 1992; the Union opposed and Confesor issued a cease-and-desist order on 15 October 1992.
On 25 January 1993 Confesor issued an Omnibus Resolution: she denied MII’s partial motion to overturn the illegality ruling as to the 94 employees and ordered payment of backwages; she referred the question of legality of the 73 layoffs to the NLRC and lifted prior prohibitory injunctions. Confesor also clarified the CBA’s closed-shop and bargaining-unit provisions, ruling that executive secretaries are excluded from the closed-shop provision but not necessarily from the bargaining unit.
The Union moved for execution on 4 February 1993; MII filed a petition for certiorari under Rule 65 alleging grave abuse of discretion, and the Supreme Court issued a Temporary Restraining Order on 4 March 1993 enjoining enforcement of the 14 April 1992 and 25 January 1993 resolutions. MII’s assigned errors challenged (A) the declaration that the 94 layoffs exacerbated the dispute and the order of reinst...(Subscriber-Only)
Issues:
- Did the Secretary of Labor and Employment commit grave abuse of discretion or exceed her jurisdiction in declaring the layoff of 94 employees illegal and ordering their reinstatement with backwages?
- Did the Secretary commit grave abuse of discretion in treating executive secretaries as part of the bargaining unit (i.e., in not excluding certain executive secretaries from the...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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