Case Summary (G.R. No. 97622)
Procedural Background
The genesis of this dispute traces back to a petition filed on September 4, 1990, by Regalado de Mesa on behalf of URTMSEU, seeking the conduct of an election among union officers. The Department of Labor and Employment (DOLE) med-arbiter, Rolando S. de la Cruz, ordered the election to be held on November 15, 1990, following a pre-election conference where both parties agreed on the election procedure. The election results displayed a tie between the two groups, each securing 133 votes, while 6 ballots were deemed spoiled.
Election Controversy
Subsequent to the election, Catalino Algire filed a motion regarding a particular ballot deemed spoiled due to containing two marks. Algire argued that this indicated a clear intent to vote for his group and should count as a valid vote. The agreed procedure permitted re-examination of the spoiled ballots, leading to the discovery that the questioning ballot indeed contained two checks marking support for Algire, prompting the med-arbiter to validate this ballot and declare Algire's group as the elected officers on December 20, 1990.
Appeal and Decision by the Secretary of Labor
Regalado de Mesa appealed the med-arbiter's decision to the Secretary of Labor. On January 31, 1991, the Secretary reversed the med-arbiter's ruling, ordering a new election for the URTMSEU officers instead. This decision indicated a significant procedural shift as it sought to nullify the results of the previous election, thereby engendering further contention between the two groups.
Motion for Reconsideration and Petition for Certiorari
Following the Secretary's decision, Algire's group filed a motion for reconsideration, which was denied, asserting that their rights were compromised. They contended that the Secretary had erred in interpreting the relevant provisions of the Labor Code in relation to intra-union activities, ultimately leading them to file a petition for certiorari to challenge the Secretary's ruling. It was notably claimed that the Secretary lacked jurisdiction and that the decision was unsupported by substantial evidence.
Supreme Court's Ruling
The Supreme Court analyzed the arguments presented by Algire's group and concurred that the Secretary of Labor correctly categorized the election as a consent election rather than a certification election under existing labor regulations. The Court elucidated that the representation officer's ruling on the validity of the questioned ballot was aligned with the intent
...continue readingCase Syllabus (G.R. No. 97622)
Case Overview
- This case involves a petition for certiorari filed by Catalino Algire and other officers of the Universal Robina Textile Monthly Salaried Employees Union (URTMSEU) against Regalado De Mesa and the Honorable Secretary of Labor.
- The petition seeks to nullify the decision dated January 31, 1991, made by the Secretary of Labor which reversed the earlier decision made by Med-Arbiter Rolando S. de la Cruz declaring the petitioners as duly-elected officers of URTMSEU.
- The case centers around the election for union officers to represent URTMSEU in collective bargaining with Universal Robina Textile.
Background of the Case
- On September 4, 1990, URTMSEU, represented by Regalado De Mesa, petitioned the Department of Labor and Employment (DOLE) for an election of union officers.
- Med-Arbiter Rolando S. de la Cruz issued an order on October 19, 1990, directing that an election be held.
- The election took place on November 15, 1990, with results showing a tie between the two contending groups (Lino Algire's group and Regalado De Mesa's group), each receiving 133 votes, and 6 spoiled ballots.
Election Dispute
- Following the election, Catalino Algire filed a protest regarding the validity of a specific ballot (the "questioned ballot") that contained two checks, arguing it should not have been labeled spoiled.
- During the hearing, it was confirmed that