Case Summary (G.R. No. 81852-53)
Relevant Procedural History
A petition for certiorari was filed to annul several orders and decisions, including the February 4, 1987 order by Labor Arbiter Manuel P. Asuncion, the May 29, 1987 decision by the same Arbiter, and the resolutions issued by the National Labor Relations Commission (NLRC) on October 12, 1987, and January 11, 1988. The case emerged from a memorandum of agreement signed on December 3, 1986, concerning the ratification of the CBA by union members on December 7, 1986.
Facts of the Case
At the general meeting of December 7, 1986, a resolution was passed to approve the CBA, which included a provision for a special assessment of P1,098.00 from each union member's CBA differential pay. Despite the majority vote in favor, private respondents protested this deduction and refused to authorize it. Consequently, they were expelled from the union via a resolution on January 6, 1987, leading to complaints filed by the private respondents against IBM and SMC for illegal deductions and wrongful expulsion.
Jurisdictional Issues and Labor Code Provisions
The petitioner contested the jurisdiction of the NLRC over the complaints filed by the private respondents. Jurisdiction over the subject matter is defined by law and is primarily determined by the allegations presented in the complaint. The complaints concerned not just the assessment and deductions but also the private respondents' rights as union members, thereby categorizing them as intra-union disputes.
According to Article 226 of the Labor Code, the Bureau of Labor Relations has jurisdiction over intra-union disputes, which encompasses conflicts arising from any violation of union by-laws or members' rights, excluding cases directly related to collective bargaining agreements that undergo grievance procedures or arbitration.
Conclusion of the Labor Arbiter and NLRC Decisions
The Labor Arbiter ruled against the petitioner's assessments and expulsion
...continue readingCase Syllabus (G.R. No. 81852-53)
Case Background
- The case involves a petition for certiorari filed by the petitioner, ILAW AT BUKLOD NG MANGGAGAWA (IBM), against the National Labor Relations Commission (NLRC), Labor Arbiter Manuel P. Asuncion, and private respondents Antonio Magsipoc, Abundio Ibasco, Carlos Villarante, and Bienvenido Ramirez.
- The petition seeks to annul multiple orders and resolutions issued by the Labor Arbiter and the NLRC regarding labor disputes.
Parties Involved
- Petitioner: ILAW AT BUKLOD NG MANGGAGAWA (IBM), a duly-registered labor union representing daily-paid workers of San Miguel Corporation (SMC) in Metro Manila.
- Respondents: National Labor Relations Commission, Labor Arbiter Manuel P. Asuncion, and private respondents (employees) Antonio Magsipoc, Abundio Ibasco, Carlos Villarante, and Bienvenido Ramirez.
Relevant Facts
- A Memorandum of Agreement was signed between the petitioner and SMC on December 3, 1986, pertaining to a Collective Bargaining Agreement (CBA).
- The National Council of the petitioner held a general meeting on December 7, 1986, to ratify the CBA, where a resolution was passed to present it to the general membership.
- A significant majority (2,107 out of 2,243) of attending members ratified the CBA.
- The resolution included an assessment of ₱1,098.00 from each member’s CBA differential, which was met with protest by private respondents, leading to their refusal to sign