G.R. No. 77539 - Associated Labor Unions vs. Trajano

Petitioner: Domiciano Soco, who was employed as a driver for Mercantile Corporation of Davao (MERCO) and also served as the President of the MERCO Employees Labor Union (MELU), an affiliate of the Federation of Free Workers (FFW).
Private Respondent: Mercantile Corporation of Davao, a company engaged in the sale and distribution of ice cream.
Other Respondent: The Honorable Amado G. Inciong, Deputy Minister of Labor, who later affirmed the disciplinary order.

Soco’s Role: As a driver, Soco’s duties included delivering ice cream using the company vehicle.
Union Leadership: Soco was actively involved in union activities, including efforts to transfer his union’s affiliation from FFW to Southern Philippines Federation of Labor (SPFL).
Company Rule: Company Rule No. 19(a) prohibited the use of the company vehicle for personal or unauthorized union purposes, prescribing a suspension for the first offense and dismissal for subsequent violations.

On January 25, 1979, Soco deviated from his usual delivery route to visit a co-employee during off-duty hours, an act linked to his union activities.
Responding to reports, the personnel officer investigated and summoned Soco to provide an explanation, but he did not comply.
On January 30, 1979, when MERCO called for a grievance conference via the FFW, Soco refused to participate, expressing his belief that such a conference was unnecessary.
MERCO imposed a suspension of five (5) days effective February 15, 1979, for violating the company rule.

On February 13, 1979, during his delivery assignments, Soco went to the office of the SPEL Union instead of following his assigned route.
In the presence of union officials and company personnel, the MERCO manager inspected the company vehicle and discovered irregularities.
Again, Soco was summoned to explain his unauthorized deviation but failed to do so.
Following these events, on February 14, 1979, Soco filed a complaint for unfair labor practice against MERCO, alleging that his discipline—initially a five-day suspension—was a pretext tied to his union activities.

MERCO simultaneously filed an application for clearance to terminate Soco’s employment and responded to the unfair labor practice complaint.
The two cases (termination clearance and the unfair labor practice complaint) were consolidated and tried jointly by the Regional Director of the Ministry of Labor.
On May 21, 1979, the Regional Director granted MERCO’s application to terminate Soco’s employment, upheld the preventive suspension, and dismissed the unfair labor practice complaint.

Soco appealed the decision, which led to the review by the Deputy Minister of Labor.
On October 25, 1979, the Deputy Minister affirmed the Regional Director's decision.
Soco then filed a petition for certiorari challenging the administrative orders on grounds of grave abuse of discretion and alleged lack of jurisdiction, citing Policy Instruction No. 6 of the Ministry of Labor and Employment regarding jurisdiction over unfair labor practice cases.

Whether the Regional Director had proper jurisdiction to hear and decide the unfair labor practice complaint, given that Policy Instruction No. 6 allegedly vests exclusive original jurisdiction in the Conciliation Section of the Ministry of Labor.
Whether Soco’s voluntary submission to the jurisdiction of the Regional Director constituted a waiver of any subsequent jurisdictional challenge.

Whether the dismissal and termination of Soco’s employment were justified based on the evidence of his violation of Company Rule No. 19(a) on two separate occasions.
Whether the disciplinary measures imposed were proportionate given Soco’s long tenure (18 years) and the alleged minimal damage caused by his actions.

Whether Soco’s failure to attend scheduled grievance conferences or present explanations invalidated the disciplinary proceedings.
Whether the administrative findings, being supported by substantial evidence, effectively precluded a reexamination on appeal.