Case Digest (G.R. No. 250627)
Facts:
In Philippine Phosphate Fertilizer Corporation v. Hon. Ruben D. Torres (G.R. No. 98050, March 17, 1994), the Philippine Phosphate Fertilizer Corporation (PHILPHOS) challenged two Department of Labor and Employment (DOLE) rulings directing a certification election among its supervisory, professional/technical, and confidential employees. On July 7, 1989, the Philphos Movement for Progress, Inc. (PMPI) filed a petition for certification election to represent PHILPHOS’s supervisory staff. PHILPHOS did not oppose the petition but sought to exclude its superintendents (managerial) and professional/technical employees. On October 13, 1989, Mediator-Arbiter Milado ordered an election among supervisory employees only. On November 15, 1989, PMPI amended its petition to include professional/technical and confidential employees, and by agreement of the parties on December 14, 1989, the case was submitted for decision on position papers. On March 28, 1990, Milado directed a broader electionCase Digest (G.R. No. 250627)
Facts:
- Initiation of Certification Election
- On 7 July 1989, Philphos Movement for Progress, Inc. (PMPI) filed with the Department of Labor and Employment (DOLE) a petition for certification election among the supervisory employees of Philippine Phosphate Fertilizer Corporation (PHILPHOS).
- On 11 August 1989, PHILPHOS submitted a position paper welcoming a supervisory union but seeking to exclude its superintendents (managerial) and professional/technical employees (non-supervisory).
- On 13 October 1989, Mediator-Arbiter Milado ordered a certification election among supervisory employees, excluding superintendents and professional/technical staff, and set a pre-election conference for 19 April 1990.
- Amended Petition, Appeals, and Supreme Court Intervention
- On 15 November 1989, PMPI filed an amended petition to include supervisory, professional/technical (engineers, analysts, mechanics, accountants, nurses, midwives), and confidential employees in the proposed bargaining unit.
- On 28 March 1990, the Mediator-Arbiter granted the amended petition and directed an election among supervisory, professional/technical, and confidential employees.
- On 16 April 1990, PHILPHOS appealed to the Secretary of Labor and Employment, who on 7 August 1990 dismissed the appeal; recon- sideration was denied.
- On 8 July 1991, the Supreme Court issued a temporary restraining order enjoining respondents from holding the certification election scheduled on 12 July 1991, and PHILPHOS filed the present petition for certiorari (G.R. No. 98050).
Issues:
- Was PHILPHOS denied due process when the Mediator-Arbiter granted PMPI’s amended petition without a new hearing?
- Can PHILPHOS’s professional/technical and confidential employees validly join a supervisory union such as PMPI?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)