Title
Uson vs. PLDT Employees Credit Cooperative
Case
G.R. No. 253149
Decision Date
Feb 8, 2023
Julius Uson, PECCI's General Manager, was dismissed in 2017; the Supreme Court ruled his case as an intra-cooperative dispute under CDA jurisdiction, voiding labor tribunal decisions and ordering refunds.

Case Digest (G.R. No. 229881)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Julius R. Uson (Uson) was the General Manager of PLDT Employees Credit Cooperative (PECCI) before his alleged dismissal on April 21, 2017.
    • Uson was an active member of PECCI since 1981 and held various positions including committee secretary and director prior to General Manager appointment.
    • PECCI is a cooperative registered with the Cooperative Development Authority (CDA), existing under Philippine laws.
    • Respondents Noel P. Santos, Jesus L. Siy, Miguel B. Dawis, and Sergio P. Navarra were incumbent directors of PECCI at the time of the dispute.
  • Uson’s Appointment and Tenure
    • On October 10, 2013, the PECCI Board of Directors passed a resolution appointing Uson as Acting General Manager until a regular General Manager was hired.
    • Uson’s appointment as General Manager was formalized on May 19, 2014, effective May 22, 2014, pursuant to a board resolution approving his hiring as a regular employee and reappointment as General Manager.
    • His appointment was ratified by the PECCI Representative Assembly on March 28, 2015.
  • Dismissal and Related Board Resolution
    • On April 17, 2017, PECCI’s Board of Directors declared all appointive positions vacant, including that of the General Manager, under the premise of the need for trust and confidence in new officers.
    • A letter was sent on April 20, 2017, instructing Uson to turn over all PECCI properties under his control.
    • A memorandum circulated naming Santos, Siy, Dawis, and Navarra as new directors of PECCI.
  • Legal Proceedings Prior to the Supreme Court
    • On May 30, 2017, Uson filed a complaint for illegal dismissal before the Labor Arbiter (LA), claiming regular employee status and praying for reinstatement, backwages, and damages.
    • PECCI argued that Uson was a cooperative officer and the dispute was intra-cooperative, falling under CDA jurisdiction according to the Cooperative Code (RA 9520).
    • The LA ruled Uson a regular employee and found the dismissal illegal, awarding separation pay and backwages.
    • PECCI and Uson both appealed to the National Labor Relations Commission (NLRC).
    • NLRC partly granted Uson’s appeal and dismissed PECCI’s appeal, asserting jurisdiction over the case.
    • Motions for reconsideration by both parties were denied by the NLRC.
  • Court of Appeals Decision
    • The Court of Appeals (CA) consolidated PECCI and Uson’s petitions and ruled in favor of PECCI.
    • The CA found the labor tribunals lacked jurisdiction, categorizing the dispute as an intra-cooperative matter proper for the CDA.
    • The CA ordered Uson to return any monetary amounts received pursuant to the labor tribunal’s decisions.
    • Uson’s motion for reconsideration was denied.
  • Present Petition
    • Uson filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, arguing:
      • The NLRC has jurisdiction over illegal dismissal cases including his;
      • He was a regular employee illegally dismissed;
      • He is entitled to reinstatement, benefits, damages, and attorney’s fees;
      • The respondent directors are personally liable for bad faith dismissal.

Issues:

  • Whether the dispute involving Uson’s dismissal as General Manager of PECCI is an intra-cooperative dispute within the jurisdiction of the Cooperative Development Authority (CDA) or an ordinary labor dispute properly cognizable by the labor tribunals.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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