Title
Philippine Dairy Products Corp. vs. Genilo
Case
G.R. No. 106705
Decision Date
Sep 26, 1994
The Supreme Court upheld the Voluntary Arbitrator's orders regarding the execution of its resolution, rejecting claims of grave abuse of discretion and bias by Philippine Dairy Products Corporation against San Miguel Corporation.
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Case Digest (G.R. No. 106705)

Facts:

  • The case involves Philippine Dairy Products Corporation and San Miguel Corporation - Magnolia Dairy Products Division as petitioners against Voluntary Arbitrator Tito F. Genilo and the National Organization of Workingmen (NOWM) as respondents.
  • The events began with the Supreme Court's August 30, 1989 Resolution in G.R. No. 85577, which dismissed a petition for lack of merit.
  • Individual private respondents, members of the respondent union, were laborers supplied by Skillpower Corporation and Lipercon Services, Inc.
  • Upon expiration of their service contracts, they were denied entry to the petitioners' premises.
  • The private respondents and the union filed separate complaints for illegal dismissal with the National Labor Relations Commission (NLRC).
  • Labor Arbiter Tito F. Genilo ruled on July 29, 1988, declaring the private respondents as regular employees and ordered their reinstatement with backwages.
  • Following a motion for execution, Genilo issued an order on October 20, 1988, directing the regularization of all complainants.
  • Petitioners contested this order, arguing that private respondents should meet certain requirements before reinstatement.
  • The case was remanded for execution on November 6, 1989, with hearings conducted in October 1989, where petitioners failed to appear.
  • The Voluntary Arbitrator approved the lists of employees for reinstatement submitted by the private respondents.
  • Petitioners filed a motion for reconsideration, claiming lack of notification for the hearings and thus denial of due process.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that there was no grave abuse of discretion by the Voluntary Arbitrator in ordering the regularization and reinstatement of similarly situated employees, even if they were not originally part of the arbitration case.
  • The Court upheld that petitioners could refu...(Unlock)

Ratio:

  • The Supreme Court emphasized that the August 29, 1989 Resolution indicated that regularization is a labor benefit applicable to all qualified employees similarly situated, regardless of their party status in the arbitration case.
  • The Court noted that the intention during voluntary arbitration was to resolve all issues comprehensively, allowing the Volunta...continue reading

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