G.R. No. 238805 - Spouses Liu vs. Court of Appeals

Paper Industries Corporation of the Philippines (PICOP) is engaged in the manufacture of paper and timber products, with over 9,000 employees. Of these, 944 are supervisory and technical staff employees, and approximately 487 are signatory members of the PICOP-Bislig Supervisory and Technical Staff Employees Union (PBSTSEU).
Respondents include Undersecretary Bienvenido E. Laguesma (DOLE), Regional Director Henry Pabel (DOLE Regional Office No. XI), PBSTSEU, the Federation of Free Workers (FFW), and the Associated Labor Union (ALU).

August 9, 1989: PBSTSEU filed a petition for certification election among supervisory and technical staff. PICOP requested additional time to file comments but failed to do so. FFW and ALU intervened; Med-Arbiter Gamolo granted interventions and scheduled the election with four choices (PBSTSEU, FFW, ALU, no union).
September–November 1989: PICOP appealed the Med-Arbiter’s order for lack of due process and asserted PBSTSEU’s lack of personality. Secretary of Labor Drilon, on November 17, 1989, affirmed the order with modification to include employees in Cebu, Davao, and Iligan.
January 18, 1990: During the pre-election conference, PICOP objected to including certain section heads and supervisors, claiming they were reclassified managerial employees under a new organizational structure.

PICOP’s Revised Organizational Structure (implemented January 1991) decentralized the company into four business groups—each led by a vice-president or assistant vice-president, with divisions headed by managers and sections led by section/unit managers (formerly section heads and supervisors).
March 27, 1990: Med-Arbiter Phibun D. Pura issued an order declaring the subject supervisors and section heads as managerial employees, excluding them from the voter list.
April 17 and August 7, 1991: Undersecretary Laguesma reversed the Med-Arbiter’s order, holding that the disputed positions are supervisory (not managerial) and thus eligible to vote; PICOP’s motions for reconsideration were denied.
April 12, 2000: PICOP filed a petition for certiorari with the Supreme Court to annul the DOLE resolutions of April 17 and August 7, 1991.

Whether section managers and unit managers exercise independent hiring and firing authority sufficient to qualify as managerial employees under Article 245 of the Labor Code.
Whether the actual job descriptions and functions of these positions support a finding of managerial status or supervisory status.

Whether Undersecretary Laguesma committed grave abuse of discretion by denying PICOP’s request to present additional evidence on the post-petition implementation of its reorganization program.
Whether Laguesma disregarded PICOP’s documentary evidence and relied solely on PBSTSEU’s allegations of a sham reorganization.