Case Summary (G.R. No. 202131)
Applicable Law
The decision is based on the 1987 Constitution of the Philippines and relevant provisions from the Labor Code, particularly Articles 224 and 232 concerning employer-employee relationships and the jurisdiction of the Department of Labor and Employment (DOLE) and Labor Arbiters.
Facts and Antecedent Proceedings
In 2002, ABS-CBN implemented the IJM system, which profiles freelance workers (IJM workers) across various technical and creative positions. The AIWU, which comprises 1,101 IJM workers, sought to be recognized as their exclusive bargaining agent, filing a petition for a certification election on November 23, 2009. However, ABS-CBN opposed the petition, claiming no employer-employee relationship existed between the company and the IJM workers, citing prior rulings from the National Labor Relations Commission (NLRC).
Mediator-Arbiter’s Decision
The Mediator-Arbiter dismissed AIWU's petition for a certification election on April 14, 2010, affirming the lack of an employer-employee relationship based on existing decisions in previous cases (Payonan and Jalog). Consequently, AIWU appealed this decision to the DOLE Secretary, who later ruled in favor of AIWU, reversing the Mediator-Arbiter's order.
DOLE Secretary’s Ruling
On August 13, 2010, the DOLE Secretary concluded that significant evidence indicated the existence of an employer-employee relationship, thus granting AIWU's petition for a certification election. The Secretary highlighted that the IJM workers performed essential functions for ABS-CBN and had a relationship akin to employees, consistent with the findings in similar prior cases.
Court of Appeals’ Ruling
ABS-CBN sought to overturn the DOLE Secretary's decision in the Court of Appeals, which ruled that the existence of an employer-employee relationship is a question of fact needing detailed examination by the labor arbiter. The appellate court found that the DOLE overstepped its jurisdiction by making a determination on employment status, as previous rulings by the NLRC were still pending appeal.
Supreme Court’s Review
The Supreme Court, in its examination, determined that the DOLE Secretary acted within her jurisdiction by finding an employer-employee relationship based on substantial evidence. The Court emphasized that the Bureau of Labor Relations has the authority to determine this r
...continue readingCase Syllabus (G.R. No. 202131)
Case Background
Parties Involved:
- Petitioner: ABS-CBN IJM Workers Union (AIWU)
- Respondent: ABS-CBN Corporation
Nature of the Case:
- The petition seeks the reversal of the Court of Appeals' Decision and Resolution that overturned the Department of Labor and Employment (DOLE) Secretary's ruling, which had granted AIWU's appeal for a certification election.
Core Issue:
- The fundamental issue pertains to the existence of an employer-employee relationship between ABS-CBN and the IJM workers represented by AIWU.
Facts and Antecedent Proceedings
Corporate Background:
- ABS-CBN Corporation is engaged in broadcasting television and radio content in the Philippines.
- In 2002, ABS-CBN introduced the Internal Job Market System (IJM), a database listing technical or creative manpower who offer their services.
Formation of AIWU:
- IJM workers, including various technical personnel, formed AIWU, which is registered with the DOLE.
Petition for Certification Election:
- On November 23, 2009, AIWU filed a petition for a certification election among 1,101 IJM workers, supported by signatures from 33.51% of the bargaining unit.
Respondent's Opposition:
- ABS-CBN opposed the petition, claiming no employer-employee relationship existed with the IJM workers, citing previous rulings from the National Labor Relations Commission (NLRC) that favored ABS-CBN.
Mediator-Arbiter's Order
Initial Ruling:
- On April 14, 2010, the Mediator-Arbiter denied AIWU's petition for a certification election, citing a lack of employer-employee relationship.
Reasoning:
- The Mediator-Arbiter noted that the DOLE must respect the NLRC's prior findings in favor of ABS-CBN regarding the employment status of IJM workers.
DOLE Secretary's Ruling
Decision