Case Summary (G.R. No. 110399)
Procedural Background
The union filed a certification‐election petition on October 5, 1990. On December 19, 1990, the Med‐Arbiter ordered a single election for all supervisory and exempt employees across the three plants. SMC appealed on January 18, 1991, challenging both the consolidation of plants into one unit and the inclusion of supervisory levels 3–4 and exempt employees. On July 23, 1991, Undersecretary Laguesma remanded the case for precise classification. Following reconsideration, separate elections by plant and by supervisory levels 1–4 and exempt categories were set on September 3, 1991. SMC sought further reconsideration on September 21, 1991. On March 11, 1993, the Undersecretary excluded supervisors 3–4 and exempt employees from the unit, citing Philips Industrial Development.
Confidential Employee Classification
The Court analyzed whether supervisory levels 3–4 and exempt employees qualify as “confidential employees,” who assist in labor‐relations policy and thus are barred from bargaining‐unit membership. Managerial employees under Article 245 are ineligible to join rank‐and‐file unions but may organize separately. Confidential status demands both (1) confidential assistance to labor‐relations policy‐makers and (2) routine access to labor‐relations information essential to job performance.
Analysis of Supervisors’ Functions and Information Access
The job functions of supervisory levels 3–4 and exempt employees—quality control, production decisions, sanitation oversight, material recall and rejection—concern internal business operations and technical data (product formulas, standards), not labor‐relations policy. Even incidental access to employer business secrets does not confer confidential status under labor‐relations doctrine. Therefore, these employees do not meet the cumulative criteria for exclusion.
Right to Collective Bargaining under the 1987 Constitution
Article XIII, Section 3 of the 1987 Constitution guarantees all workers the right to self‐organization. Exclusion of confidential employees must be narrowly construed to avoid undue deprivation of collective‐bargaining rights. Since the questioned employees do not qualify as confidential, they retain the constitutional right to join or form a union and to participate in certification elections.
Appropriateness of a Single Bargaining Unit
An appropriate unit groups employees sharing substantial mutual interests in wages, hours, and working conditions. Supervisory leve
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Facts
- On October 5, 1990, the San Miguel Corporation Supervisors and Exempt Union filed with the Department of Labor and Employment (DOLE) a petition for district certification or certification election covering supervisory and exempt employees at the Magnolia Poultry Products plants in Cabuyao, San Fernando, and Otis.
- On December 19, 1990, Med-Arbiter Danilo L. Reynante ordered a single certification election among all supervisors and exempt employees across the three plants.
- San Miguel Corporation appealed on January 18, 1991, challenging the consolidation of the three plants into one unit and the inclusion of supervisory levels 3 and 4 and exempt employees as confidential.
- On July 23, 1991, Undersecretary Bienvenido E. Laguesma granted the appeal and remanded the case for proper employee classification.
- Upon the union’s motion, reconsideration was granted on September 3, 1991, and separate certification elections were ordered for supervisory levels 1–4 and exempt employees in each plant.
- San Miguel Corporation moved for reconsideration and suspension of proceedings on September 21, 1991.
- On March 11, 1993, Undersecretary Laguesma granted the motion, excluded supervisory levels 3 and 4 and exempt employees from the bargaining unit, and barred their participation in the election, citing the Philips Industrial Development, Inc. v. NLRC doctrine.
- The petitioners then sought certiorari and preliminary injunction before the Supreme Court to set aside the March 11, 1993 Order.
Issues
- Whether supervisory employees at levels 3 and 4 and the exempt employees are “confidential employees” and thus ineligible to join a union or participate in a certification election.
- If they are not confidential employees, whether the supervisory and exempt employees of the three Magnolia Poultry Products plants constitute an appropriate single bargaining unit.
Confidential Employee Rule
- Confidential employees are those who both assist in a confidential capacity and