G.R. No. 191699 - William Go Que Construction vs. Court of Appeals

The existing 2001–2004 Collective Bargaining Agreement (CBA) was nearing expiration (April 30, 2004), which prompted the parties to begin negotiations for a new CBA.
Early meetings focused on setting the ground rules and discussing political items prior to addressing the economic issues.

On July 27, 2004 (the 31st meeting), the union proposed a 20% annual across-the-board basic salary increase for three years under the new CBA.
The company countered with a proposal to grant all covered employees an annual lump-sum amount of ₱80,000 for the three-year period.
The union demanded that the company present its counter-proposal in full detail, comparable to the union’s detailed economic proposal.
The company explained that its lump-sum offer was based on its affordability, relative salary levels in the industry, and the total pay-and-benefits package available to employees.
Dissatisfied with the explanation, the union pressed for further justification; however, the company refused to provide additional details, leading the union to reject the counter-offer and maintain its demand for a wage increase.
In subsequent meetings, the union lowered its demand to a 12% annual increase while the company raised its lump-sum counter-offer to ₱88,000 per year.
The union requested additional financial data and a comparative analysis of allied industries’ salaries, but the company cited confidentiality and pointed to readily available data on its scorecards and website, further deepening the dispute.

On September 2, 2004 (the 41st meeting), the company proposed declaring a deadlock and suggested the involvement of a third party, but the union instead filed a Notice of Strike with the National Conciliation and Mediation Board (NCMB), alleging bad faith bargaining by the company.
In response, the NCMB convened conciliation-mediation proceedings, which failed to produce an amicable settlement.
During the cooling-off period, following a unanimous strike vote by union members, the company filed a Petition for Assumption of Jurisdiction with the Secretary of Labor and Employment under Article 263(g) of the Labor Code, citing the potential impact of a strike on industries vital to the national interest.
On September 20, 2004, the Secretary of Labor and Employment granted the petition, officially assuming jurisdiction over the labor dispute and enjoining any form of strike or concerted action until further resolution, while ordering both parties to submit detailed position papers.

The union filed a petition for certiorari in the Court of Appeals (CA-G.R. SP No. 88178) on January 13, 2005, alleging grave abuse of discretion by the Secretary for assuming jurisdiction over economic issues which, according to the union, were outside the scope of its Notice of Strike.
The Court of Appeals rejected the union’s petition, referencing existing jurisprudence (e.g., St. Scholastica’s College v. Torres) that affirmed the Secretary’s authority over all questions and controversies arising from a labor dispute in industries indispensable to the national interest.

Between February and June 2005, separate proceedings ensued, including a complaint for unfair labor practice filed by the union with the National Labor Relations Commission and consolidation of the issues by the Labor Arbiter.
On June 8, 2005, the Secretary of Labor and Employment rendered a Decision whereby she found a de facto bargaining deadlock between the parties despite the union’s separate allegation of unfair labor practice.

The Decision found that there was no bad faith on the company’s part since the company had maintained its bargaining position per its economic offer.
The Secretary ruled that, for lack of the union’s position paper substantiating its wage increase demand, a lump-sum package of ₱95,000 per year per employee was just and equitable for the new CBA (May 1, 2004 – April 30, 2007).
Other benefits from the previous CBA were retained.

Neither party appealed the Decision, resulting in its finality and executory status.

The union, dissatisfied with the earlier proceedings, pressed its contentions before the Supreme Court.
It argued that (a) the company engaged in unfair labor practices by bargaining in bad faith, (b) a CBA deadlock and bad faith bargaining cannot coexist, and (c) the declaration of deadlock was improper without mutual consent as mandated by the ground rules.
The company defended the Secretary’s assumption of jurisdiction, arguing that the entirety of the labor dispute, including the economic issues and the procedural notion of deadlock, fell within the Secretary’s authority.

Whether the Secretary of Labor and Employment had the authority under Article 263(g) to assume jurisdiction over all aspects of the labor dispute, including economic issues related to the new CBA, even if the union’s initial complaint focused solely on alleged bad faith bargaining.

Whether a de facto bargaining deadlock existed between the parties despite the absence of a mutual declaration of deadlock as per the ground rules agreed upon by the union and the company.
Whether the failure to present additional justifications by the company constituted bad faith bargaining or was merely a reflection of its bargaining stance.

Whether the union’s petition, challenging the final Decision of the Secretary of Labor and Employment dated June 8, 2005, is barred by res judicata and moot due to the conclusiveness and finality of the earlier adjudication.
Whether the issues raised by the union are essentially questions of fact that are improper for review under a petition for certiorari under Rule 45 of the Rules of Court.