G.R. No. 188448 - Laygo vs. Municipal Mayor of Solano, Nueva Vizcaya

In February 1997, the Supreme Court ruled that employees of Toyota Motor Philippines Corporation (TMPC) holding Level 5 positions under its Single Salary Structure were supervisory employees.
The decision became final and executory, but shortly after, TMPC implemented its Three-Function Salary Structure, which purportedly reclassified employees based on actual functions as either supervisory or rank-and-file.

On February 4, 1999, TMPCWA, the union representing TMPC workers, filed a petition for a certification election before the Med-Arbitration Unit of DOLE-NCR for rank-and-file employees at the Sta. Rosa and Bicutan Plants.
TMPC opposed the petition by arguing that the union’s membership overlapped with that of a previously registered union (TMPCLU) whose registration had been cancelled, and that the petition was a mere rehash of a petition dismissed in 1998.
Initially, the petition was dismissed by Med-Arbiter Zosima C. Lameyra on March 29, 1999, but was subsequently reversed on appeal by the DOLE on June 25, 1999, which ordered the certification election to proceed.

The certification election was held on March 8, 2000, during which the inclusion and exclusion proceedings were conducted on February 15, 2000.
TMPC submitted a list containing 1,110 employees; however, TMPCWA challenged the eligibility of 120 employees on the basis that they were supervisory employees as per the earlier Supreme Court ruling.
During the election, 105 of the 120 challenged employees cast votes, which were ultimately not counted by the election authorities. The recorded results were:

TMPCWA claimed victory by asserting that the majority of valid votes were in its favor, while TMPC contended that without counting the 105 challenged votes, the union’s affirmative votes were 22 votes short of a required majority.

The Med-Arbiter, on May 12, 2000, issued an order certifying TMPCWA as the exclusive bargaining agent after excluding the challenged votes on the basis that those voters were classified as supervisory employees.
TMPC appealed this order before DOLE, arguing that the challenged voters were in fact rank-and-file employees whose votes should have been counted.
Several motions and petitions ensued:

The challenged voters sought declaratory relief in separate litigation, questioning their classification.
TMPC intervened, contesting the qualification of these voters, but the Labor Arbiter and later DOLE maintained that the challenged voters were supervisory employees, thus excluding them from the certification election count.

Amid the contested election results, TMPC engaged in negotiations and submitted counter-proposals regarding the proposed collective bargaining agreement (CBA).
A period of industrial unrest followed, including a strike initiated by TMPCWA on March 28, 2001, which later ceased when the SOLE assumed jurisdiction over the dispute.
TMPC, arguing that it had a material interest, filed a petition for certiorari under Rule 65 with the Court of Appeals (CA) on March 27, 2001, challenging the decisions of DOLE and the Med-Arbiter.
The CA, on June 29, 2001, ordered a preliminary injunction restraining TMPCWA from enforcing certain resolutions pending the termination of the litigation.
On July 27, 2001, TMPCWA filed a petition for certiorari with the Supreme Court alleging grave abuse of discretion by the CA in issuing the writ of preliminary injunction.

Whether the 105 challenged voters should be classified as supervisory employees (thus ineligible to vote as rank-and-file) or as rank-and-file employees.
The impact of the Supreme Court’s earlier decision in Toyota Motor Philippines Corporation v. Toyota Motor Philippines Corporation Labor Union, in light of TMPC’s subsequent adoption of the Three-Function Salary Structure.

Whether TMPC, as the employer, is a proper party with standing to contest the certification election results and seek injunctive relief.
Whether the CA committed grave abuse of discretion in granting a writ of preliminary injunction in favor of TMPC, particularly given the conflicting positions regarding the employer's role as a mere bystander in a certification election.

Whether the decisions and actions of the DOLE, the Med-Arbiter, and the Labor Arbiter, in excluding or counting challenged votes, fell within their proper jurisdiction under labor law.
Whether there existed an emergency or imminent injury warranting the issuance of a preliminary injunction by the CA, and if such equity was necessary given the resolution of the strike and other changes in circumstances.