G.R. No. 96025 - Parungao vs. Sandiganbayan

On 27 February 2001, Confederated Labor Union of the Philippines (CLUP), on behalf of its local chapter, filed a petition for certification election covering the regular rank-and-file employees of Sta. Lucia East Commercial Corporation (SLECC) and its affiliates, in Case No. RO400-0202-RU-007.
The affiliates included SLE Commercial, SLE Department Store, SLE Cinema, Robsan East Trading, Bowling Center, Planet Toys, Home Gallery, and Essentials.
On 21 August 2001, Med-Arbiter Bactin dismissed the petition for being an inappropriate bargaining unit.
CLUP-Sta. Lucia East Commercial Corporation and its Affiliates Workers Union appealed this dismissal on 14 September 2001 but moved to withdraw the appeal on 20 November 2001; the withdrawal was granted on 31 January 2002, affirming dismissal.

On 10 October 2001, CLUP-Sta. Lucia East Commercial Corporation and its Affiliates Workers Union reorganized and re-registered as Sta. Lucia East Commercial Corporation Workers Association (SLECCWA), limiting membership to rank-and-file employees of SLECC only, receiving Certificate No. RO400-0110-CC-004.
On the same date, SLECCWA filed a new petition for direct certification alleging they had over 20% membership among rank-and-file employees, and no election had been held within 12 months.
Although Samahang Manggagawa sa Sta. Lucia East Commercial (SMSLEC) was registered on 22 June 2001 covering the same employees, it was not officially recognized as exclusive bargaining agent.

On 22 November 2001, SLECC moved to dismiss SLECCWA’s petition, alleging voluntary recognition of SMSLEC as the exclusive bargaining agent on 20 July 2001 and ongoing collective bargaining negotiations, invoking one-year and negotiation bar rules under the Omnibus Rules Implementing the Labor Code.
On 29 November 2001, SLECC and SMSLEC ratified a collective bargaining agreement (CBA), which was registered on 9 January 2002.

On 19 December 2001, SLECCWA filed an opposition citing invalidity of voluntary recognition due to the existence of another certified labor organization (SLECCWA itself) and alleged malice, collusion, and conspiracy involving DOLE Regional Office officials and Med-Arbiter Bactin.
They argued that the voluntary recognition of SMSLEC violated legal requirements as SLECCWA was a legitimate registered labor organization at that time.

On 29 July 2002, Med-Arbiter Bactin dismissed SLECCWA’s petition on grounds of contract bar rule based on prior voluntary recognition and CBA with SMSLEC, granting SMSLEC exclusive bargaining rights.
SLECCWA appealed to the Secretary of Labor and Employment, who reversed the Med-Arbiter’s ruling on 27 December 2002, ordering a certification election among the three options: SLECCWA, SMSLEC, or No Union.
The Secretary directed cancellation of the voluntary recognition in favor of SMSLEC and noted that SLECCWA had valid registration prior to that recognition.
SLECC filed a motion for reconsideration which was denied on 27 March 2003.
SLECC then filed a petition for certiorari before the Court of Appeals, which affirmed the Secretary’s decision on 14 August 2003 and denied SLECC’s petition on 24 February 2004.

Whether the voluntary recognition of SMSLEC by SLECC was valid and whether it barred SLECCWA’s petition for direct certification.
Whether the existence of a legitimate labor organization (SLECCWA) at the time of voluntary recognition could invalidate such recognition and the consequent contract bar.
Whether the employer (SLECC) could file a motion to dismiss or oppose the petition for certification election filed by another labor organization.