Case Summary (G.R. No. 233300)
Case Background
The legal proceedings began when Coca-Cola filed for cancellation of the Union's certification, alleging that the union’s members included managers who were ineligible to be union members under the Labor Code of the Philippines. Coca-Cola's motion was initially denied by the Department of Labor and Employment (DOLE) Regional Office and later affirmed by the Bureau of Labor Relations.
Relevant Procedural History
In March 2017, the Court of Appeals denied Coca-Cola's certiorari petition under Rule 65 for failing to follow procedural requirements, specifically the need to file a motion for reconsideration before appealing to the court. The appellate court referenced Article 239 of the Labor Code, which outlines the permissible grounds for union registration cancellation.
Key Legal Issues
The essential legal question pertains to whether the inclusion of certain employees within the union constituted a valid ground for canceling its registration. Coca-Cola argued that the union had managerial employees whose involvement should disqualify the union under existing labor laws.
Findings of the DOLE Regional Office
The DOLE Regional Office ruled in favor of the Union, stating that there was no evidence of grounds for cancellation, specifically pointing out there was no instance of misrepresentation or fraud during the union's formation or operation. The Regional Office found that employees outside the bargaining unit could not invalidate the registration, as they would automatically be removed from union membership.
Decisions of the Bureau of Labor Relations
Coca-Cola's subsequent appeal to the Bureau of Labor Relations was denied, which reaffirmed the DOLE’s decision. The Bureau determined that proper grounds for cancellation of a labor organization’s registration, as defined by the Labor Code, had not been substantiated by Coca-Cola.
Appellate Court Ruling
Upon reaching the Court of Appeals, Coca-Cola's petition was dismissed based on both procedural grounds—as they failed to file a necessary motion for reconsideration—and substantive grounds, as the appellate court concurred with earlier findings that no valid grounds for cancellation existed under the Labor Code.
Supreme Court Decision
The Supreme Court ultimately affirmed the Court of Appeals' ruling, reiterating that a motion for reconsideration is required unless certain exceptions apply. The Court maintained that Coca-Cola had not proved any of the grounds permi
...continue readingCase Syllabus (G.R. No. 233300)
The Case
- This case involves a petition for review on certiorari under Rule 45 of the Rules of Court by Coca-Cola FEMSA Philippines, Inc. (Coca-Cola).
- The petition challenges the March 16, 2017 Decision and July 31, 2017 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 148045.
- The CA denied Coca-Cola's petition for certiorari under Rule 65, citing the failure to file a motion for reconsideration and inability to prove any grounds under Article 239 (now Article 247) of the Labor Code.
Background of the Case
- Coca-Cola is a domestic corporation involved in manufacturing carbonated drinks and other beverages.
- The respondent, Central Luzon Regional Sales Executive Union, represents the sales executives of Coca-Cola in Central Luzon (Pampanga, Bataan, Zambales, and Tarlac).
- On October 28, 2015, the Union sought recognition as the certified bargaining agent for the sales executives.
- On January 21, 2016, Coca-Cola filed a petition for cancellation of the Union's registration, claiming that its members included managers who were ineligible to join a labor organization.
Allegations and Claims
- Coca-Cola asserted that the sales executives had transitioned from being classified as supervisory to now performing managerial functions, which included responsibilities such as business planning, performance management, and personnel management.
- The company contended that the sales executives routinely directed the work of other employees and had the authority to recommend hiring and discipline actions.
- Conversely, the Union maintained that its