Title
Supreme Court
University of the Immaculate Conception vs. Office of the Secretary of Labor and Employment
Case
G.R. No. 178085-178086
Decision Date
Sep 14, 2015
Labor dispute between UIC and its employees' union over wage increases tied to tuition fees and illegal dismissal of 12 employees; Secretary of Labor's authority upheld, tripartite committee affirmed, dismissals valid but procedural lapses led to nominal damages.

Case Digest (G.R. No. 164584)
Expanded Legal Reasoning Model

Facts:

  • Background of the labor dispute
    • The University of the Immaculate Conception (UIC), a non-stock, non-profit educational institution in Davao City, and the UIC Teaching and Non-Teaching Employees Union-FFW (the “Union”) have been in dispute since June 1994.
    • The Union, as certified bargaining agent, filed a notice of strike on June 20, 1994, over bargaining deadlock and alleged unfair labor practices.
  • Voluntary arbitration and termination of employees
    • On July 20, 1994, NCMB-mediated talks led to agreement on tuition-fee increment shares (75% first year, 80% second and third years); UIC sought exclusion of certain personnel as confidential employees.
    • An arbitration panel (Nov. 8, 1994) sustained UIC’s exclusion of twelve employees from the bargaining unit. After denial of reconsideration (Feb. 8, 1995), UIC gave the affected employees the choice to resign from the Union or keep their posts. When they refused to resign, UIC issued termination notices on February 21, 1995.
  • Secretary of Labor’s intervention and earlier court actions
    • The Secretary assumed jurisdiction (OS-AJ-003-95) on January 23, 1995; on March 28, 1995 he suspended the terminations and ordered “payroll reinstatement.” UIC’s certiorari petition against that order was denied by the CA (Oct. 8, 2001) and this Court (Jan. 14, 2005).
    • In June 2006, the Secretary found the dismissals illegal and ordered substantive reinstatement with backwages. UIC’s motion for reconsideration was denied (Sept. 18, 2006).
  • Dispute over net incremental proceeds
    • The parties signed an April 21, 2004 agreement providing for computation of net incremental proceeds (1995–2000) by comparison of actual distributions versus CBA entitlements; UIC later rescinded the clause to facilitate signing of the June 8, 2004 CBA.
    • The Union moved for a tripartite committee (May 17, 2004); the Secretary granted it (July 5, 2004), denied UIC’s reconsideration (May 19, 2005), and in a second resolution (Sept. 18, 2006) ordered distribution of ₱11,070,473 to employees.
  • Court of Appeals and Supreme Court proceedings
    • UIC filed two certiorari petitions in the CA (Nov. 20, 2006): one challenging the tripartite committee and computation (“Net Incremental Proceeds Case”) and the other the illegality of the dismissals (“Illegal Dismissal Case”); the CA consolidated and denied both (Apr. 24, 2007; motions for reconsideration denied May 31, 2007).
    • UIC petitioned this Court raising the same issues and, separately, moved to cite a non-lawyer (Olvida) for contempt for preparing pleadings. A TRO was issued (July 9, 2007).

Issues:

  • Does the Secretary of Labor have authority under Article 263(g) of the Labor Code to create a tripartite committee to compute net incremental proceeds?
  • Was the computation of net incremental proceeds (₱11,070,473) proper, and were UIC’s claimed deductions rightly disallowed?
  • Were the dismissed employees—classified as confidential employees—lawfully terminated for maintaining union membership?
  • Did UIC comply with procedural due process (two-notice requirement) in the terminations?
  • Was Alfredo Olvida, a non-lawyer who prepared and filed pleadings, guilty of unauthorized practice of law (indirect contempt)?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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