Case Digest (G.R. No. 127374)
Facts:
Philippine Skylanders, Inc., et al., G.R. Nos. 127374 and 127431, January 31, 2002, Supreme Court Second Division, Bellosillo, J., writing for the Court. The petitions for certiorari sought to set aside the National Labor Relations Commission’s (NLRC) 31 July 1996 Decision affirming the Labor Arbiter’s 30 June 1995 Decision that found petitioners guilty of unfair labor practice and ordered payment of P150,000 to private respondent Philippine Association of Free Labor Unions (PAFLU) September; the petitions also challenged the NLRC’s 31 October 1996 resolution denying reconsideration.In November 1993 the local union Philippine Skylanders Employees Association (PSEA), affiliated with PAFLU, won a certification election at Philippine Skylanders, Inc. (PSI). A rival union filed an election protest with the Secretary of Labor. While that protest was pending, PSEA sent PAFLU a notice of disaffiliation, adopted by a resolution of its officers and members, and then affiliated with the National Congress of Workers (NCW), becoming PSEA-NCW. PSI recognized PSEA-NCW and, on 17 March 1994, entered into a collective bargaining agreement (CBA) with it that was registered with the Department of Labor and Employment.
PAFLU Secretary General Serafin Ayroso demanded PSI’s audited financials and, after being rebuffed by PSI’s personnel manager Francisco Dakila on grounds of disaffiliation, filed consolidated complaints for unfair labor practice against PSI, its president Mariles C. Romulo, Dakila, and later against the elected officers of PSEA-PAFLU. Ayroso alleged interference with union activities and refusal to bargain. The Labor Arbiter, in a 30 June 1995 Decision, declared PSEA’s disaffiliation invalid, found PSI, PSEA-PAFLU and their officers guilty of unfair labor practice, struck down the PSEA-NCW CBA, and awarded PAFLU P150,000 in damages.
PSI, PSEA-NCW and the officers appealed to the NLRC, which on 31 July 1996 affirmed the Labor Arbiter, reasoning that an election protest pending before the Secretary of Labor prevented valid disaffiliation, and thus the CBA and recognition were invalid. Motions for reconsideration were denied. Petitions for certiorari to the Supreme Court were filed (one instituted 23 December 1996) and later consolidated; the Solicitor General filed a ...(Pro-only)
Issues:
- Did the Labor Arbiter and the NLRC have jurisdiction to resolve the dispute or was the matter an inter-union controversy properly before the Bureau of Labor Relations?
- Was PSEA’s disaffiliation from PAFLU valid while an election protest was pending, and therefore was PSEA free to affiliate with NCW and enter into a collective bargaining agreement with PSI?
- Did PAFLU have legal personality to file the unfair labor practice complaint on behalf of the local, and could PSI and its officers be held liable for unfair labor ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)