Case Summary (G.R. No. 142666)
Applicable Law
The decisions pertaining to this case are based on the 1987 Philippine Constitution, alongside applicable provisions from the Labor Code of the Philippines, particularly Articles 217, 260, and 261 regarding grievances, collective bargaining agreements, and the jurisdiction of labor arbiters.
CBA and Grievance Machinery Provisions
On February 11, 1997, the Petitioner and Respondent entered into a CBA that included a detailed grievance machinery. The provisions outlined processes for handling disputes and complaints by employees, with clear steps for resolution leading up to potential voluntary arbitration, except for specific cases of termination or unfair labor practices.
Actions Taken by the Respondent
The Respondent's president initiated grievance meetings in July and August 1997 concerning issues related to health insurance and salesmen's incentive schemes. Following unsuccessful discussions, the Respondent submitted requests for voluntary arbitration and provided lists of arbitrators, which the Petitioner failed to reciprocate, leading the Respondent to lodge a complaint for unfair labor practice against the Petitioner.
Petitioner’s Motion to Dismiss
In response to the Respondent's complaint, the Petitioner filed a motion to dismiss based on lack of jurisdiction, arguing that the issues fell exclusively under the purview of a voluntary arbitrator as defined in the CBA and applicable labor statutes. However, the Respondent contended that the Petitioner’s failure to engage in the grievance process made resolution through the labor arbiter appropriate.
Labor Arbiter's Decision
The Labor Arbiter denied the Petitioner's motion to dismiss on March 19, 1998, requiring both parties to file position papers. The Petitioner subsequently elevated the matter to the Court of Appeals, alleging that there had been grave abuse of discretion by the Arbiter for asserting jurisdiction over the complaint.
Court of Appeals’ Findings
The Court of Appeals found merit in the Arbiter's decision, emphasizing that jurisdictional issues raised by the Petitioner could be addressed through the position papers and in the eventual appeal after the Arbiter's decision, rather than through a direct petition for certiorari.
Supreme Court's Conclusion
The Supreme Court affirmed the lower court's decision
...continue readingCase Syllabus (G.R. No. 142666)
Case Background
- The case is a petition for review on certiorari filed by Metro Drug Distribution, Inc. (petitioner) against the Metro Drug Corporation Employees Association a Federation of Free Workers (respondent).
- The petition seeks to reverse the Decision dated 17 September 1999 and the Resolution dated 27 March 2000 of the Court of Appeals in CA-G.R. SP No. 47642.
- The Court of Appeals dismissed the petitioner's certiorari petition.
Parties Involved
- Petitioner: Metro Drug Distribution, Inc., a corporation engaged in distributing consumer products.
- Respondent: Metro Drug Corporation Employees Association a Federation of Free Workers, the recognized collective bargaining representative of the rank-and-file employees of the petitioner.
Collective Bargaining Agreement (CBA)
- A CBA was entered into on 11 February 1997, which includes a grievance machinery provision.
- Key provisions of the grievance machinery:
- Definition of Grievance: Any dispute between the Company and the Union, or any employee complaint regarding the interpretation or violation of the CBA, labor laws, employee dismissal, or labor-management relations.
- Preliminary Steps: Employees must first bring grievances to immediate supervisors for adjustment.
- Grievance Processing Steps:
- Step 1: Discuss with department head; escalate if unresolved.
- Step 2: File with Vice-President of Human Resources; three-day resolution timeline.
- Step 3: If unresolved, file with the Company President for determination.
- Voluntary Arbitration: Disputes not resolved through the grievance procedure are to be referred for voluntary arbitration, except for termination and unfair labor practice cases which may go to compulsory arbitration.
Events Leading to Dispute
- On 08 July 1997, the respondent union's president requested discussions regarding grievances, including health insurance and salesmen'