Title
San Miguel Corp. Supervisors and Exempt Union vs. Laguesma
Case
G.R. No. 110399
Decision Date
Aug 15, 1997
A union sought certification for supervisors and exempt employees across three San Miguel plants. The Supreme Court ruled they are not confidential employees and can form a single bargaining unit due to shared interests.

Case Digest (G.R. No. 110399)

Facts:

San Miguel Corporation Supervisors and Exempt Union and Ernesto L. Ponce, President v. Honorable Bienvenido E. Laguesma, et al., G.R. No. 110399, August 15, 1997, Supreme Court Second Division, Romero, J., writing for the Court. Petitioners are the San Miguel Corporation Supervisors and Exempt Union (represented by Ernesto L. Ponce); respondents are Bienvenido E. Laguesma (Undersecretary of Labor and Employment), Danilo L. Reynante (the Med-Arbiter), and San Miguel Corporation.

On October 5, 1990 the petitioner union filed with the Department of Labor and Employment (DOLE) a Petition for District Certification or Certification Election to cover supervisors and exempt employees of San Miguel Corporation (SMC) Magnolia Poultry Products Plants at Cabuyao, San Fernando and Otis. On December 19, 1990 Med-Arbiter Danilo L. Reynante ordered a certification election treating the three plants and the covered supervisory and exempt employees as a single bargaining unit.

SMC appealed the Med-Arbiter's order. On July 23, 1991 Undersecretary Bienvenido E. Laguesma granted the appeal and remanded the case to the Med-Arbiter to determine proper classification of employees. After the union sought reconsideration, Undersecretary Laguesma on September 3, 1991 directed separate certification elections for supervisors levels 1 to 4 (S1–S4) and exempt employees in each of the three plants. SMC filed a motion for reconsideration with a motion to suspend proceedings on September 21, 1991.

On March 11, 1993 Undersecretary Laguesma granted SMC’s motion and, citing Philips Industrial Development, Inc. v. NLRC, excluded supervisory levels 3 and 4 and the so-called exempt employees from participation in the proposed bargaining unit on the ground that they were confidential employees. The Undersecretary thus modified his September 3, 1991 order to bar S3, S4 and exempt employees from the certification election. Peti...(Subscriber-Only)

Issues:

  • Are supervisory employees level 3 and 4 and the exempt employees of SMC confidential employees and thus ineligible to join the union and to participate in the certification election?
  • If they are not confidential employees, do the employees of the three Magnolia Poultry plants constitute an appropriate ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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