Case Digest (G.R. No. L-37452)
Facts:
- The case involves the Union of Supervisors in Litex (USIL) as the petitioner and the Court of Industrial Relations (CIR), the Association of Democratic Labor Organizations (ADLO), and the Labor Relations Division, Bureau of Labor Relations, Department of Labor as respondents.
- On January 19, 1973, ADLO filed a petition with the CIR to be certified as the exclusive bargaining agent for all supervisors at Lirag Textile Mills, Inc. (Litex).
- USIL and the Managers, Division Superintendents and Supervisors Union (MDSSU) intervened against ADLO's petition.
- Seventy employees, claiming to represent over ten percent of the 476 supervisors at Litex, intervened with USIL's counsel.
- ADLO contested the intervention, arguing that these seventy employees were top management and ineligible to join the supervisory unit.
- Litex presented employee lists categorizing them into regular supervisors, confidential supervisors, and purely confidential employees.
- The CIR ordered a certification election on June 16, 1973, excluding confidential employees and certain managerial personnel.
- USIL and intervenors filed motions for reconsideration, which were denied on August 25, 1973.
- USIL filed a petition for certiorari and prohibition against the CIR, ADLO, and the Labor Relations Division on September 12, 1973, challenging the orders of Judge Paredes.
- USIL raised a jurisdictional issue, claiming the National Labor Relations Commission (NLRC) had exclusive jurisdiction under Presidential Decree No. 21.
- On June 3, 1974, Letter of Instructions No. 191 directed the CIR to transfer pending cases to the Bureau of Labor Relations.
- By September 19, 1974, USIL and the Labor Relations Division expressed no objection to dismissing the case, while ADLO sought a ruling on the eligibility of purely confidential employees.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the case was moot and dismissed it, affirming that the National Labor Relations Commission had exclusive jurisdiction over certification cases.
- The Court did not resolve the issue regarding the eligibility of purely confidential employees and top ...(Unlock)
Ratio:
- The Supreme Court's decision focused on the jurisdictional question raised by USIL regarding the authority of the CIR versus the NLRC.
- The Court noted that the NLRC was established under Presidential Decree No. 21, granting it original and exclusive jurisdiction over employer-employee relation...continue reading
Case Digest (G.R. No. L-37452)
Facts:
The case involves the Union of Supervisors in Litex (USIL) as the petitioner and the Court of Industrial Relations (CIR), the Association of Democratic Labor Organizations (ADLO), and the Labor Relations Division, Bureau of Labor Relations, Department of Labor as respondents. The events leading to this case began on January 19, 1973, when ADLO filed a petition with the CIR seeking certification as the exclusive bargaining agent for all supervisors at Lirag Textile Mills, Inc. (Litex), which operates in Malabon and Montalban, Rizal. The USIL, formerly known as LUSO, and the Managers, Division Superintendents and Supervisors Union (MDSSU) intervened in opposition to ADLO's petition. On February 23, 1973, seventy employees, claiming to represent more than ten percent of the 476 supervisors employed by Litex, also intervened, with their counsel being the lawyer for USIL. The ADLO contested the intervention, arguing that these seventy employees were top management personnel and purely confidential or technical employees, thus ineligible to join the supervisory unit or petition for a certification election.
During the hearings, Litex presented lists categorizing its employees into regular supervisors, confidential supervisors, and purely confidential employees. USIL and MDSSU agreed to include all employees listed as regular supervisors, while ADLO consented to include regular supervisors but sought to exclude certain employees it deemed non-supervisors and all purely confidential employees. On June 16, 1973, the CIR, presided over by Judge Ansberto P. Paredes, ordered the Department of Labor to conduct a certification election among the supervisory employees of Litex, excluding the confidential employees and certain managerial personnel. Following this, USIL and the intervenors filed motions for reconsideration, which were denied by the CIR on August 25, 1973. Subsequently, on September 12, 1973, USIL filed a petition for certiorari and prohibition against the CIR, ADLO, and the Labor Relations Division, challenging the orders of Judge Paredes. The petition was accepted, and a restraining order was issued against the certification election.
In the proceedings, USIL raised a new issue regarding the jurisdiction of the CIR over certification cases, arguing that the N...