Case Digest (G.R. No. 192302)
Facts:
San Miguel Foods, Incorporated v. San Miguel Corporation Supervisors and Exempt Union, G.R. No. 146206, August 01, 2011, Supreme Court Third Division, Peralta, J., writing for the Court. Petitioner is San Miguel Foods, Incorporated (SMFI); respondent is San Miguel Corporation Supervisors and Exempt Union (the Union).The dispute traces to this Court's earlier decision in San Miguel Corporation Supervisors and Exempt Union v. Laguesma, G.R. No. 110399, which held that supervisory employees levels 3 and 4 and exempt employees of the Magnolia Poultry Products Plants at Cabuyao, San Fernando, and Otis were not confidential employees and therefore could form an appropriate bargaining unit. Pursuant to that ruling, DOLE-NCR conducted pre-election conferences to effect a certification election for the bargaining unit encompassing those plants.
A Med-Arbiter ordered a certification election, held September 30, 1998. Petitioner and respondent submitted discrepant voter lists; petitioner challenged the eligibility of numerous voters on several grounds (e.g., confidential status, assignment to live chicken operations not covered by the unit, employment outside SMFI, membership in other unions). The initial tally produced many segregated ballots; after segregates were opened, the Med-Arbiter found a strong affirmative vote and issued an order certifying respondent as exclusive bargaining agent for supervisors and exempt employees of the cited plants.
On administrative appeal the Acting DOLE Undersecretary (Resolution dated July 30, 1999) affirmed the Med-Arbiter's order but excluded four named individuals from the bargaining unit; reconsideration was denied. The Court of Appeals, in CA-G.R. SP No. 55510 (Decision dated April 28, 2000), affirmed with modification the DOLE resolution and held that those holding the positions of Human Resource Assistant and Personnel Assistant are confidential employees and must be excluded from the bargaining unit; the CA denied petitioner's motion for partial reconsideration (Resolution dated November 28, 2000). Petitioner then filed the pres...(Subscriber-Only)
Issues:
- Did the Court of Appeals depart from jurisprudence when it expanded the scope of the bargaining unit defined by this Court in G.R. No. 110399?
- Did the Court of Appeals depart from jurisprudence—specifically this Court's definition of a confidential employee—when it ruled for the inclusion of the Payroll Master position in the bargaining unit?
- Is this petition a rehash or resurrection of the issues ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)