Case Summary (G.R. No. 102084)
Applicable Law
The relevant laws include the 1987 Philippine Constitution, specifically the provisions on the right to self-organization, and Articles 245 and 257 of the Labor Code of the Philippines, as amended, which govern the organization rights of supervisory employees and the process for certification elections.
Background and Initial Proceedings
The case began when the Federation of Free Workers recognized FFW-DLSUMCCMSUC as a local union affiliated with it and subsequently filed a petition for a certification election among DLSUMCCM's supervisory employees. DLSUMCCM contested the petition on the grounds that some employees who signed it were managerial personnel, thus not eligible to participate in such a union and pointing out that FFW-DLSUMCCMSUC included both supervisory and rank-and-file employees.
Med-Arbiter's Decision
On July 5, 1991, the med-arbiter recognized the validity of the petition for election, stating the need for a certification election based on the evidence of supervisory employees being present in DLSUMCCM, and emphasized that the supervisory and rank-and-file employees constituted separate bargaining units, thereby allowing them to be affiliated with the same national federation without breaching Article 245's provisions.
Appeal and Secretary of Labor's Resolution
Petitioner appealed the med-arbiter's decision, asserting the same arguments regarding the managerial status of certain employees and the alleged violation of union affiliation provisions. The Secretary of Labor dismissed the appeal, finding insufficient evidence to support claims of managerial status, and cited a precedent affirming the legality of unions formed independently by supervisory and rank-and-file employees to affiliate with the same federation.
Grounds for Certiorari and Petitioner's Contentions
DLSUMCCM filed a petition for certiorari, claiming that the Undersecretary acted with grave abuse of discretion by denying their appeal and ordering the election, which contradicted Article 245. The key argument posited by DLSUMCCM revolved around the potential merging of supervisory and rank-and-file interests, which could undermine their separate bargaining rights.
Supreme Court Decision
The Supreme Court upheld the Law Secretary's decision, citing the constitutional guarantee of self-organization for supervisory employees, indicating that they indeed have the right to form unions distinct from rank-and-file unions. It clarified that supervisory employees are not barred from affiliation with the same national federation as rank-and-file unions, provided they do n
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Case Overview
- The case involves the petitioner, De La Salle University Medical Center and College of Medicine (DLSUMCCM), a hospital and medical school located in Dasmariñas, Cavite.
- The respondents include the Honorable Bienvenido E. Laguesma, Undersecretary of Labor and Employment, Rolando S. De La Cruz, Med-Arbiter of the Department of Labor and Employment Regional Office No. IV, and the Federation of Free Workers De La Salle University Medical Center and College of Medicine Supervisory Union Chapter (FFW-DLSUMCCMSUC), a labor organization for supervisory employees of DLSUMCCM.
- The case arose from a petition for a certification election filed by FFW-DLSUMCCMSUC, which was opposed by DLSUMCCM based on the claim that some petitioning employees were managerial and that the union included both supervisory and rank-and-file employees.
Background of the Case
- On April 17, 1991, the Federation of Free Workers issued a certificate recognizing FFW-DLSUMCCMSUC as a local chapter.
- The petition for certification election was filed on the same day, which DLSUMCCM contested, arguing that the petition included managerial employees and was thus invalid.
- DLSUMCCM claimed that supervisory employees were improperly associating with rank-and-file employees, violating Article 245 of the Labor Code, which mandates that supervisory employees cannot join rank-and-file unions.
Proceedings and Orders
- On July 5, 1991, the Med-Arbiter, Rolando S. De La Cru