Case Digest (G.R. No. 87700)
Facts:
In San Miguel Corporation Employees Union-PTGWO et al. v. Hon. Jesus G. Bersamira and San Miguel Corporation (G.R. No. 87700, June 13, 1990), the petitioners, led by the San Miguel Corporation Employees Union-PTGWO, challenged the Regional Trial Court of Pasig, Branch 166 for issuing a Preliminary Injunction on March 29, 1989 in Civil Case No. 57055 entitled *San Miguel Corporation vs. SMCEU-PTGWO, et al.*. San Miguel Corporation (SanMig) had engaged Lipercon Services, Inc. and DRite Service Enterprises in 1983–1984 as independent contractors to supply merchandising services, with explicit contractual clauses denying any employer-employee relation. Meanwhile, a Collective Bargaining Agreement (CBA) from July 1, 1986 to June 30, 1989 between SanMig and the Union excluded temporary, probationary, and contractual workers from the bargaining unit. In November 1988 the Union demanded that long-serving contractual workers of Lipercon and DRite be regularized by SanMig, alleging a laboCase Digest (G.R. No. 87700)
Facts:
- Parties and Subject Matter
- Petitioners: San Miguel Corporation Employees Union-PTGWO (Union) and rank-and-file employees seeking to represent contractual workers of Lipercon Services, Inc. and DRite Service Enterprises.
- Respondents: Hon. Jesus G. Bersamira (Presiding Judge, RTC Branch 166, Pasig) and San Miguel Corporation (SMC).
- Relief sought below: Preliminary injunction and damages to enjoin union activities targeting SMC’s contractual workers.
- Contracts and Collective Bargaining Agreement (CBA)
- In 1983–1984, SMC contracted out merchandising services to Lipercon and DRite, expressly excluding their workers from any employee status with SMC.
- The Union and SMC executed a CBA effective July 1, 1986–June 30, 1989, which similarly excluded temporary, probationary, or contract employees from the bargaining unit.
- Union Demands and Strike Notices
- November 20, 1988: Union demanded regularization of Lipercon and DRite workers who claimed labor-only contracting status.
- January 12 and 30, 1989: Notices of strike filed for alleged unfair labor practices and CBA violations; conciliation conferences held before the NCMB-DOLE.
- February 14–March 2, 1989: Picketing by contractual workers at various SMC sites.
- Proceedings in the RTC
- March 6, 1989: SMC filed a verified complaint for preliminary injunction and damages in Civil Case No. 57055.
- March 11, 1989: RTC denied Union’s motion to dismiss for lack of jurisdiction.
- March 25 & 29, 1989: RTC issued an order granting preliminary injunction and the corresponding writ after bond posting.
- April 24, 1989: SC issued a temporary restraining order enjoining implementation of the RTC injunction and directed the restoration of status quo ante strike.
Issues:
- Whether the RTC had jurisdiction to entertain SMC’s application for preliminary injunction in a dispute involving contractual workers.
- Whether the controversy constitutes a “labor dispute” under Article 212(1) of the Labor Code despite the absence of a direct employer-employee relationship.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)