Case Digest (G.R. No. 91025)
Facts:
Union of Filipro Employees sought certiorari against the National Labor Relations Commission (NLRC) resolutions dated June 5, 1989 and August 8, 1989 in Certified Case No. 0522, arising from a collective bargaining agreement (CBA) deadlock with Nestle Philippines, Inc. The CBAs for several Nestle units had expired; while UFE was certified as bargaining representative for Cagayan de Oro (June 10, 1987) and Cebu/Davao (July 28, 1987), the company terminated union officers following a strike staged without notice of strike and without a strike vote, a ruling upheld by the NLRC en banc.
Upon Labor Secretary Franklin Drilon’s certification for compulsory arbitration limited to the Makati, Alabang, and Cabuyao units, the NLRC Second Division issued a resolution granting wage increase and directing the parties to execute a CBA covering those units, while absolving the company of unfair labor practice. The union’s motions for reconsideration and for modification of the certified issue failed, hence this petition.
Issues:
- Whether the NLRC Second Division acted without jurisdiction because the certified dispute was not decided by NLRC en banc.
- Whether the CBA to be signed should cover only the Makati, Alabang, and Cabuyao bargaining unit.
- Whether the NLRC committed grave abuse of discretion in ruling that the CBA was effective only upon promulgation of the resolution.
- Whether the NLRC erred in denying the union’s demands for a contract signing bonus and disregarded long-standing company practice.
- Whether the NLRC erred in refusing the union’s demand for a modified union shop security clause in the CBA.
- Whether the NLRC erred in absolving the company of the unfair labor practice charge despite alleged incriminatory evidence.
Ruling:
The Court held that the NLRC Second Division had jurisdiction to resolve the certified deadlock because R.A. 6715 and Administrative Order No. 36 (Series of 1989) required NLRC adjudication through divisions, not en banc, for adjudication purposes.
It further held that the NLRC properly limited the CBA to the sole issue certified by the Secretary of Labor, refused to amend the certification order in the compulsory arbitration proceedings, and correctly implemented the CBA with prospective effect since the retroactivity regime in Art. 253-A required agreement within the statutory six-month period. The Court sustained the NLRC on the denial of the union’s demanded CBA terms and ruled that the findings of fact of the NLRC were conclusive absent grave abuse of discretion, but it set aside the NLRC portion absolving the company of unfair labor practice.
Ratio:
The enactment of R.A. 6715 amended Art. 213 of the Labor Code, authorizing NLRC to exercise adjudicatory powers through its divisions and limiting en banc sittings to rule-making and policy formulation; Administrative Order No. 36 then directed cessation of en banc adjudication effective March 21, 1989. As a consequence, continuing to require en banc decision for this certified dispute found no legal justification.
On the merits, the Court treated the Secretary’s certification for compulsory arbitration as a time-sensitive measure of police power to prevent a prolonged strike or lockout, and it ruled that the NLRC could only implement the certification’s scope and not modify it (consistent with University of Santo Tomas v. NLRC, UST Faculty Union, G.R. No. 89920, October 18, 1990). The Court applied Art. 253 and Art. 253-A (as amended by R.A. 6715) to conclude that while parties must maintain status quo during the statutory period, retroactive effect for renegotiated provisions depended on agreement entered into within six months from expiry; absent such agreement, prospective effect followed. On the requested CBA provisions, the Court found no grave abuse and relied on the principle that the NLRC’s factual findings on CBA terms are conclusive in the absence of a clear showing of arbitrariness.
Doctrine:
- After R.A. 6715, the NLRC exercises adjudicatory powers through its divisions, and en banc sittings for adjudication are not required.
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