Case Summary (G.R. No. 192648)
Background of Union Registration
On September 26, 2003, a union registration was issued to Bigkis Manggagawa sa De Ocampo Memorial Medical Center - LAKAS (BMDOMMC). Subsequently, on December 5, 2003, BMDOMSI was granted a Union Registration/Certificate of Creation for its local chapter. On March 4, 2004, the Petitioner filed a petition with the Department of Labor and Employment (DOLE) seeking to cancel BMDOMSI's registration based on allegations of misrepresentation, mixed membership, and setting up an inappropriate bargaining unit.
Petitioner’s Allegations
The Petitioner asserted that BMDOMSI misrepresented facts by sharing members and leadership with BMDOMMC. It contended that the union included a mix of rank-and-file and managerial employees and claimed that the bargaining unit was inappropriate, which would ground a petition for cancellation under labor laws. The Petitioner further stated that a supplemental petition was filed highlighting the status of BMDOMMC’s registration cancellation.
Initial Rulings by DOLE
In a ruling on July 26, 2004, DOLE affirmed the allegations of misrepresentation concerning the union's composition. It concluded that while the union claimed to represent faculty and technical employees, its actual membership predominantly covered personnel from the General Services Division, thus lacking a commonality of interest. This ruling was later appealed by BMDOMSI to the Bureau of Labor Relations (BLR).
BLR's Decision
On December 29, 2004, the BLR overturned the DOLE's prior decision, finding insufficient evidence of misrepresentation or fraud as alleged by the Petitioner. The BLR noted that BMDOMSI properly listed its members as rank-and-file employees fitting within the claimed occupational classifications. Furthermore, the BLR stated that even if BMDOMSI shared officers with BMDOMMC, this situation did not automatically invalidate its registration.
Court of Appeals Review
Following the BLR’s decision, the Petitioner filed a Petition for Certiorari with the Court of Appeals (CA), which ultimately upheld the BLR's ruling. The CA found no significant evidence of misrepresentation in BMDOMSI's application and concluded that allegations brought forth by De Ocampo lacked the necessary substantiation required to cancel a union's registration.
Supreme Court Decision
The Supreme Court reviewed the case and affirmed the CA's ruling. It clarified that for cancellation of a union's registration under Article 247 of the Labor Code, the grounds of misrepresentation require such serious
...continue readingCase Syllabus (G.R. No. 192648)
Case Overview
- This case involves a Petition for Review on Certiorari filed by De Ocampo Memorial Schools, Inc. (Petitioner) challenging the Decision and Resolution of the Court of Appeals (CA) related to the registration of the labor union Bigkis Manggagawa sa De Ocampo Memorial School, Inc. (Respondent).
- The primary contention revolves around allegations of misrepresentation and fraud concerning the union's registration and its legitimacy as a labor organization.
Background of the Case
- De Ocampo is a domestic corporation operating two divisions: De Ocampo Memorial Medical Center (DOMMC) and De Ocampo Memorial Colleges (DOMC).
- On September 26, 2003, a union registration was issued to Bigkis Manggagawa sa De Ocampo Memorial Medical Center (BMDOMMC).
- On December 5, 2003, the Respondent, BMDOMSI, was registered as a legitimate labor organization.
Events Leading to the Dispute
- On March 4, 2004, De Ocampo filed a Petition for Cancellation of the BMDOMSI registration, citing grounds of misrepresentation, false statements, and fraud, alleging that BMDOMSI shared officers and members with BMDOMMC.
- De Ocampo also claimed mixed membership of rank-and-file and managerial/supervisory employees, arguing that BMDOMSI formed an inappropriate bargaining unit.
- A supplemental petition was filed, providing evidence of the cancellation of BMDOMMC’s registration.