Title
Coca-Cola Bottlers Philippines, Inc. vs. Ilocos Professional and Technical Employees Union
Case
G.R. No. 193798
Decision Date
Sep 9, 2015
CCBPI contested IPTEU's certification election, claiming employees were confidential or supervisory. Courts ruled in favor of IPTEU, affirming their status as rank-and-file workers and valid bargaining agent.

Case Summary (G.R. No. 193798)

Petitioner and Respondent

Petitioner: Coca-Cola Bottlers Philippines, Inc. (CCBPI) – objected to the inclusion of certain positions in the proposed bargaining unit and sought to invalidate IPTEU’s certification election.
Respondent: Ilocos Professional and Technical Employees Union (IPTEU) – filed for certification election to represent 22 rank-and-file professional and technical employees.

Key Dates and Procedural History

• July 9, 2007 – IPTEU filed a petition for certification election before DOLE Regional Office No. 1.
• August 23, 2007 – Mediator-Arbiter granted the petition and ordered a pre-election conference.
• September 21, 2007 – Certification election conducted; CCBPI challenged 16 votes.
• October 22, 2007 – Mediator-Arbiter denied challenges, canvassed ballots, and proclaimed IPTEU winner.
• September 3, 2007 & May 6, 2008 – CCBPI’s appeals to the SOLE were denied.
• March 17, 2010 & September 16, 2010 – CA denied CCBPI’s certiorari petition.
• September 9, 2015 – Supreme Court rendered its decision under Rule 45, affirming the CA.

Legal Framework and Applicable Provisions

• 1987 Philippine Constitution – protection of the right to self-organization (Art. 3, Sec. 8; Art. 13, Sec. 3).
• Labor Code of the Philippines – Articles on collective bargaining, supervisory and confidential employee exclusions (Art. 245).
• Department Order No. 40, Series of 2003, Rule VIII, Sec. 17 – order granting certification election in an unorganized establishment is not appealable; issues to be raised by protest.

Certification Election and Mediator-Arbiter’s Decision

The Mediator-Arbiter found that the disputed positions (e.g., Financial Analysts, Quality Assurance Specialists) were neither supervisory nor confidential under labor relations doctrine. CCBPI’s refusal to submit an employee list led the arbiter to accept the union’s proposed voter roster. The election proceeded and 16 of 22 employees voted. Upon canvass, IPTEU received 14 votes and was proclaimed bargaining agent.

DOLE Secretary’s Resolution on Appeal

CCBPI raised six grounds before the SOLE: existence of IMU as incumbent bargaining agent, ineligibility of voters as confidential employees, pendency of appeal and motion to suspend. The SOLE upheld the arbiter’s rulings, emphasizing that orders for certification election in unorganized establishments are not appealable and that employees’ access to general business data did not alone render them confidential.

Court of Appeals’ Ruling

The CA affirmed the SOLE’s decision, finding no grave abuse of discretion. It held that the factual findings regarding employee status and election validity were supported by substantial evidence. The CA also noted that the IMU never opposed IPTEU’s petition, underscoring the legitimacy of the separate bargaining unit.

Classification of Confidential Employees

Under jurisprudence, an employee is “confidential” only if (1) assisting management in labor relations policy formulation and (2) obtaining confidential labor-relations information. The Supreme Court agreed that general access to financial or operational data does not meet these cumulative criteria. Hence, the challenged voters remained eligible.

Scope of Judicial Review under Rule 45

A Rule 45 petition in labor cases raises questions of law only. Factual determinations by quasi-judicial b

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