Case Digest (G.R. No. L-31839) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In United Pepsi-Cola Supervisory Union vs. Hon. Bienvenido E. Laguesma and Pepsi-Cola Products, Philippines, Inc. (G.R. No. 122226, March 25, 1998), the petitioner, United Pepsi-Cola Supervisory Union (UPSU), a registered union of supervisory employees, filed on March 20, 1995 a petition for certification election on behalf of route managers employed by Pepsi-Cola Products Philippines, Inc. The med-arbiter denied the petition on the ground that route managers are managerial employees ineligible for union membership under the first sentence of Article 245 of the Labor Code. On appeal, the Secretary of Labor and Employment, Hon. Bienvenido E. Laguesma, affirmed this denial in orders dated August 31 and September 22, 1995. UPSU then instituted a petition for certiorari before the National Labor Relations Commission (Third Division), which dismissed the petition for failure to show grave abuse of discretion. UPSU filed a motion for reconsideration, contending that Article 245’s proh Case Digest (G.R. No. L-31839) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Petitioner: United Pepsi-Cola Supervisory Union (UPSU), a union of supervisory employees of Pepsi-Cola Products Philippines, Inc. (PCPPI).
- Respondents: Hon. Bienvenido E. Laguesma (Undersecretary, DOLE) and PCPPI.
- Petition and Procedural History
- UPSU filed a petition for certification election on March 20, 1995, on behalf of PCPPI route managers.
- The Med-Arbiter denied the petition; the Secretary of Labor affirmed, holding route managers are managerial employees and thus ineligible under Art. 245, Labor Code.
- UPSU sought certiorari before the NLRC Third Division; petition dismissed for lack of grave abuse of discretion.
- UPSU’s motion for reconsideration raised the constitutional issue under Art. III, Sec. 8 of the Constitution.
- Case elevated to the Court en banc for resolution of (a) managerial vs. supervisory status and (b) constitutionality of Art. 245.
Issues:
- Are PCPPI route managers managerial employees under Art. 212(m) of the Labor Code?
- Does Art. 245’s prohibition on managerial employees forming or joining labor organizations violate Art. III, Sec. 8 of the 1987 Constitution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)