Case Digest (G.R. No. 171153) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In San Miguel Corporation Employees Union–Philippine Transport and General Workers Organization (SMCEU-PTGWO) v. San Miguel Packaging Products Employees Union–Pambansang Diwa ng Manggagawang Pilipino (SMPPEU-PDMP) (G.R. No. 171153, September 12, 2007), SMCEU-PTGWO had served since 1987 as the certified bargaining agent for all regular rank-and-file employees of San Miguel Corporation’s Corporate Staff Unit, Brewing Philippines, and Packaging Products divisions, including the Laguna plant. On June 15, 1999, PDMP issued Charter Certificate No. 112 to SMPPEU-PDMP, which filed the required documents and on July 6, 1999 obtained from the Bureau of Labor Relations (BLR) a “Certificate of Creation of Local or Chapter.” SMPPEU-PDMP then sought three separate certification elections for each division, which the DOLE-NCR Med-Arbiter dismissed for fragmenting a single bargaining unit. On August 17, 1999, SMCEU-PTGWO filed with DOLE-NCR (Case No. NCR-OD-9908-007-IRD) a petition to cancel th Case Digest (G.R. No. 171153) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner SAN MIGUEL CORPORATION EMPLOYEES UNION–PHILIPPINE TRANSPORT AND GENERAL WORKERS ORGANIZATION (SMCEU-PTGWO)
- Certified bargaining agent (1987–1997) for regular rank-and-file employees of San Miguel Corporation’s three divisions: Corporate Staff Unit (SMCSU), Brewing Philippines (SMBP) and Packaging Products (SMPP).
- Respondent SAN MIGUEL PACKAGING PRODUCTS EMPLOYEES UNION–PAMBANSANG DIWA NG MANGGAGAWANG PILIPINO (SMPPEU-PDMP)
- Chartered as a chapter of Pambansang Diwa ng Manggagawang Pilipino (PDMP); Charter Certificate No. 112 issued 15 June 1999.
- Certificate of Creation of Local/Chapter (PDMP-01) issued by the Bureau of Labor Relations (BLR) on 6 July 1999.
- Administrative Proceedings
- SMPPEU-PDMP petitions DOLE-NCR for three certification elections covering SMPP, SMCSU and SMBP; dismissed for fragmenting one bargaining unit.
- SMCEU-PTGWO files petition (No. NCR-OD-9908-007-IRD) on 17 August 1999 to cancel SMPPEU-PDMP’s registration for alleged fraud/falsification and non-compliance with the 20% membership requirement under Article 234(c), Labor Code.
- DOLE-NCR Regional Director orders cancellation on 14 July 2000 for failure to show 20% membership but dismisses fraud charges.
- BLR Decision (19 February 2001) reverses cancellation: holds (a) chartered locals need not comply with the 20% requirement; (b) PDMP, though a trade union center, is a legitimate labor organization entitled to charter locals under Department Order No. 9.
- BLR Resolution (19 June 2001) denies SMCEU-PTGWO’s motion for reconsideration.
- Judicial Proceedings
- SMCEU-PTGWO files Petition for Certiorari under Rule 65 with the Court of Appeals (CA-G.R. SP No. 66200); CA Decision (9 March 2005) affirms BLR, holds no 20% requirement for chartered locals.
- CA Resolution (16 January 2006) denies motion for reconsideration.
- SMCEU-PTGWO elevates case to the Supreme Court by Rule 45 petition, challenging the CA’s ruling that SMPPEU-PDMP need not submit names of 20% of employees.
Issues:
- Whether a trade union center (PDMP) may directly create a local or chapter under Department Order No. 9 without fulfilling the 20% membership requirement of Article 234(c) of the Labor Code.
- Whether SMPPEU-PDMP validly acquired legal personality as a legitimate labor organization without submitting the names of at least 20% of the employees in the bargaining unit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)