Case Summary (G.R. No. 180962)
Applicable Law
The case primarily invokes provisions from the Labor Code of the Philippines and the 1987 Philippine Constitution. It discusses the nature of jurisdiction assumed by the Secretary of Labor and the procedural remedies available for contesting labor decisions.
Retrenchment and Legal Proceedings
In 2007, petitioner Philtranco Service Enterprises retrenched 21 employees, prompting respondent union to file a Notice of Strike with the Department of Labor and Employment (DOLE). After failed negotiations, a decision was rendered by the Acting Secretary of Labor, Danilo P. Cruz, on June 13, 2007, which ordered reinstatement of illegally terminated employees and other remedies.
Motion for Reconsideration and Subsequent Actions
Petitioner sought reconsideration of the June 13 decision on June 25, 2007. However, in an August 15 order, the Acting Secretary declined to rule on both the motion and the union's partial appeal, citing a DOLE regulation against reconsideration of voluntary arbitrators' decisions.
Court of Appeals Findings
Dissatisfied, petitioner pursued a Certiorari and Prohibition petition before the Court of Appeals, which issued a resolution on September 20, 2007, dismissing it on procedural grounds. The Court found that a petition should have been filed under Rule 43 specific to voluntary arbitration decisions rather than under Rule 65.
Issues Presented
Petitioner assigned several errors, alleging that the Court of Appeals: (1) Misinterpreted the applicable procedural rule; (2) Incorrectly ruled the Certiorari petition was filed out of time; (3) Dismissed the petition on procedural technicalities.
Petitioner’s Argument
Petitioner contended that the proper remedy was filing a motion for reconsideration followed by a Certiorari petition, regardless of the Secretary's classification of the case under Article 263 of the Labor Code, as it involved labor relations with public interest implications.
Respondent’s Stance
The respondent countered that the Acting Secretary acted in a voluntary arbitrator capacity and thus, the decision was subject solely to a Rule 43 review. Furthermore, it claimed the Certiorari petition was filed beyond the allowable period, arguing the motion for reconsideration did not toll the time limits.
Court's Ruling
The Supreme Court granted the Petition, stating the Secretary of Labor did not limit his authority in a voluntary capacity but rather exercised jurisdiction under the Labor Code. It clarified that even if a motion for reconsideration was unauthorized, it serves as a prerequisite for Certiorari, allowing the agency the opportunity for error correction.
Timeliness of the Petition
The Court held that the 60-da
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Case Citation
- 728 PHIL. 99 SECOND DIVISION [G.R. No. 180962, February 26, 2014]
Parties Involved
- Petitioner: Philtranco Service Enterprises, Inc., represented by M/Gen. Nemesio M. Sigaya, Vice-President for Administration.
- Respondent: Philtranco Workers Union-Association of Genuine Labor Organizations (PWU-AGLO), represented by Jose Jessie Olivar.
Background of the Case
- The petitioner, Philtranco Service Enterprises, Inc., a local land transportation company, retrenched 21 employees citing business losses.
- The respondent union filed a Notice of Strike with the Department of Labor and Employment (DOLE), alleging unfair labor practices by the petitioner.
- The case was initially filed as NCMB-NCR CASE No. NS-02-028-07, which was subsequently referred to the Office of the Secretary of the DOLE, becoming Case No. OS-VA-2007-008.
DOLE Decision
- On June 13, 2007, Acting DOLE Secretary Danilo P. Cruz issued a decision ordering the reinstatement of 17 illegally terminated union officers, payment of back wages, maintenance of the current Collective Bargaining Agreement (CBA), and remittance of union dues.
Petitioner’s Motion for Reconsideration
- The petitioner filed a Motion for Reconsideration on June 25, 2007.
- The Secretary of Labor later declined to rule on both the Motion for Reconsideration and the union's Partial Appeal, stating no legal