Case Summary (G.R. No. 141471)
Petitioner
An academic institution responsible for engaging in collective bargaining with its accredited union and adhering to labor laws governing good-faith negotiations.
Respondents
AEFL, representing Letran’s nonacademic and academic staff; Eleonor Ambas, acting as union president during the 1996 renegotiation and alleged dismissal target.
Key Dates
• December 1992 – Initial union approach for mid-term CBA renegotiation.
• January 1996 – First union notice of strike on grounds of bargaining refusal and non-compliance with NLRC order.
• February 7, 1996 – Union submits CBA proposals; petitioner acknowledges receipt on February 13.
• February 15, 1996 – Union president’s work schedule unilaterally changed; grievance request denied.
• March 13, 1996 – Second strike notice filed, adding charge of Ambos’s dismissal.
• June 18, 1996 – Actual strike begins after breakdown of negotiations.
• July 2, 1996 – Secretary of Labor directs all strikers’ immediate return and reinstatement.
• December 2, 1996 – Secretary’s Order finds petitioner guilty of two counts of unfair labor practice; orders Ambas’s reinstatement with backwages.
• August 9, 1999 – Court of Appeals affirms Secretary’s Order.
• September 18, 2000 – Supreme Court issues final decision under the 1987 Constitution.
Applicable Law
• 1987 Constitution, Article XIII, Section 3 – Right of workers to self-organization and collective bargaining.
• Labor Code of the Philippines:
– Art. 248 – Prohibited employer practices interfering with self-organization.
– Art. 250(a) – Procedure in collective bargaining, including ten-day reply requirement.
– Art. 252 – Duty to bargain collectively in good faith.
• Omnibus Rules Implementing the Labor Code, Book V, Rule XI, Section 3 – Contract Bar Rule (60-day freedom period).
Factual Background
Beginning in December 1992, the incumbent union pursued renegotiation of the CBA’s remaining term. In early 1996, amidst protracted talks, AEFL submitted its proposals on February 7; petitioner delayed its response, citing pending Board of Trustees review. Shortly thereafter, petitioner altered Ambas’s work schedule and refused grievance referral. The union served successive strike notices, and on March 29 petitioner dismissed Ambas for alleged insubordination. Negotiations were later suspended on purported grounds of a rival union’s certification petition, and AEFL commenced an actual strike on June 18.
Procedural History
Labor Arbiter favored petitioner, but the NLRC reversed. The Secretary of Labor found unfair labor practice, ordering Ambos’s reinstatement. The CA dismissed petitioner’s petition for certiorari, affirming the Secretary. Petitioner elevated the matter to the Supreme Court.
Issues
- Whether petitioner’s suspension of CBA negotiations and failure to bargain in good faith constitute unfair labor practice.
- Whether the dismissal of union president Ambos improperly interfered with employees’ right to self-organization.
Analysis on Duty to Bargain
Under Art. 252 and Art. 250(a) of the Labor Code, both parties must meet promptly and in good faith; the employer must reply within ten calendar days to bargaining proposals. Petitioner’s months-long silence, repeated delays, unilateral schedule change and abrupt suspension of negotiations upon a non-compliant certification petition demonstrate bad-faith bargaining and procedural evasion. The rival union’s petition was filed outside the 60-day freedom period and
...continue readingCase Syllabus (G.R. No. 141471)
Facts
- In December 1992, the Association of Employees and Faculty of Letran (AEFL), led by then‐President Salvador Abtria, initiated renegotiation of the 1989–1994 Collective Bargaining Agreement (CBA) with Colegio de San Juan de Letran (“petitioner”).
- A new set of union officers was elected in 1992, with Eleonor Ambas succeeding Abtria as union president; Ambas sought to continue CBA talks, but petitioner claimed the draft CBA was ready for signature.
- The draft CBA was submitted to a union referendum and ultimately rejected by the members.
- Petitioner accused the union of bad‐faith bargaining before the National Labor Relations Commission (NLRC); the Labor Arbiter ruled for petitioner but the NLRC reversed on appeal.
- In January 1996, AEFL filed a notice of strike due to petitioner’s (1) refusal to remove union counsel’s name as ordered by the NLRC, and (2) refusal to bargain.
- On January 18, 1996, parties agreed to disregard the unsigned CBA and commence negotiation of a new five‐year agreement (1994–1999).
- The union submitted its proposals on February 7, 1996; petitioner acknowledged receipt on February 13 but delayed substantive response.
- On February 15, 1996, Ambas was advised of a unilateral change in her work schedule (from Mon–Fri to Tue–Sat); her request to grieve the change under the old CBA was denied.
- Frustrated by petitioner’s inaction, AEFL filed a second strike notice on March 13, 1996. Ground‐rules talks occurred on March 27; on March 29, petitioner dismissed Ambas for alleged insubordination, prompting AEFL to amend its strike notice.
- Further ground‐rules discussions on April 20, 1996 stalled when petitioner cited a rival union’s certification‐election petition as justification for suspending negotiations.
- AEFL struck on June 18, 1996; on July 2, 1996, the Secretary of Labor assumed jurisdiction, ordered returning strikers (including Ambas) to be reinstated under prior terms, and directed petitioner to readmit them. Petitioner refused to reinstate Ambas.
- Parties filed position papers by July 17, 1996. On December 2, 1996, the S