Case Summary (G.R. No. 108765)
Factual Background
ACCESS petitioned the BLR for a certification election to determine the sole and exclusive bargaining representative of rank-and-file SSS employees. The BLR ordered a certification election covering SSS central and regional offices; the election held October 11, 1991 produced a plurality for ACCESS. SSSEA filed timely protests and motions to annul the certification elections in the wake of the October 11, 1991 balloting. The BLR initially denied protests at the director level; subsequent protests concerning regional office elections were denied by Officer-in-Charge Velasco, who then certified ACCESS as the duly elected bargaining representative. SSSEA’s motion for reconsideration was denied, after which SSSEA pursued this Rule 65 petition in the Supreme Court.
Procedural Posture and Relief Sought
SSSEA invoked certiorari under Rule 65, seeking to annul and set aside BLR orders that dismissed its election protests and motions to nullify the certification election, and prayed for injunctive relief (temporary restraining order). The petition attacked the BLR’s denials and the certification of ACCESS as the exclusive bargaining representative.
Central Legal Issues Raised
- Whether SSSEA’s resort to the Supreme Court by way of certiorari was premature because it failed to exhaust administrative remedies available under the Labor Code, specifically the appeal to the Secretary of Labor and Employment under Article 259; and
- Whether the Court, in a Rule 65 certiorari proceeding, may entertain challenges that necessarily require reexamination of factual findings made by BLR officials—e.g., alleged company-initiated/controlled-union charges or the claim that elections did not occur in regional offices.
Governing Legal Principles and Standards
The Court reaffirmed the well-settled doctrine that administrative remedies must be exhausted before invoking judicial intervention. A premature petition is fatal. Article 259 provides a direct administrative appeal route from election orders or results to the Secretary of Labor and Employment. The scope of certiorari under Rule 65 is limited: the Supreme Court may intervene only for questions of jurisdiction or grave abuse of discretion by a judicial or quasi-judicial officer. The Court will not supplant the factual determinations of administrative labor officers; judicial review does not extend to reweighing evidence or revisiting the sufficiency of evidence supporting such administrative findings.
Application of Law to the Facts
SSSEA did not appeal the Director’s order of the BLR to the Secretary of Labor as contemplated by Article 259. Because SSSEA failed to avail itself of the prescribed administrative remedy, the petition to the Supreme Court was premature. Moreover, the relief sought by SSSEA implicated primarily factual determinations—whether an unfair labor-practice charge barred the election, and whether elections in the regional offices were in fact conducted—matters that require examination of evidentiary records and findings by the BLR. Such factual controversies are inappropriate for resolution in an original certiorari petition where the issue is not one of jurisdiction or grave abuse of discretion.
Reliance on Precedent and Limits of Judicial Review
The Court relied on established precedents emphasizing administrative exhaustion (e.g., Lopez v. City of Manila; University of the Philippines v. Catungal, Jr.; Carale v. Abarintos)
...continue readingCase Syllabus (G.R. No. 108765)
Nature of the Case and Relief Sought
- Special civil action for certiorari under Rule 65 of the Revised Rules of Court, filed by Social Security System Employees Association (SSSEA).
- Petition included a prayer for temporary restraining order.
- Petition sought annulment and setting aside of the Order of the Bureau of Labor Relations dismissing SSSEA’s election protests or motions to annul certification elections among rank-and-file SSS employees.
- The petition followed administrative proceedings resulting in the declaration and certification of ACCESS as the sole and exclusive bargaining representative.
Parties and Roles
- Petitioner: Social Security System Employees Association (SSSEA) (PSLINK-TUCP).
- Respondents:
- Perdita Bathan-Velasco (referred to as Perlita Bathan-Velasco), Officer in Charge, Bureau of Labor Relations (BLR).
- Alert and Concerned Employees for Better SSS (ACCESS), contending party in the certification election.
- Social Security System (SSS), employer (respondent).
- Decision authored by Justice Pardo; Davide, Jr., C.J. (Chairman), Puno, Kapunan, and Ynares-Santiago JJ., concurred.
Factual and Chronological Background
- September 28, 1989: ACCESS filed with the Bureau of Labor Relations a petition for a certification election to determine the sole and exclusive bargaining representative of rank-and-file employees of SSS.
- August 24, 1990: BLR ordered that a certification election be conducted among the rank-and-file employees of SSS in its main office and regional branches.
- October 11, 1991: Certification elections were held.
- ACCESS garnered 1,378 votes.
- SSSEA obtained 1,116 votes.
- "No Union" received 40 votes.
- Vote tallies reported in a Labor Organization Division report dated September 24, 1992 [2].
- October 16, 1991: SSSEA filed with BLR an election protest and/or motion to annul the certification election.
- March 20, 1992: Director Calleja of BLR denied SSSEA’s protest and/or motion.
- September 29, 1992: SSSEA filed an Election Protest and/or Motion to Nullify Certification Elections in the SSS Regional Office After October 11, 1991.
- November 18, 1992: Officer in Charge Velasco denied the Election Protest and/or Motion to Nullify Certification Elections in the Regional Offices After October 11, 1991, declared ACCESS the winner, and certified ACCESS as sole and exclusive bargaining representative of all rank-and-file SSS employees [3].
- January 25, 1993: Velasco denied SSSEA’s motion for reconsideration.
- Subsequent to denial of reconsideration, SSSEA filed the present petition for certiorari before the Supreme Court.
Administrative Rulings and Records
- BLR Case No. 9-12-89 is the administrative docket referenced for the BLR proceedings [1].
- The declaration and certification of ACCESS as winner and sole bargaining representative followed the denial of SSSEA’s protests at the administrative level [3].
- The Labor Organization Division report of September 24, 1992, documented the election counts cited in the administrative and judicial records [2].
Petitioner's Contentions (as presented in source)
- Petitioners argued the certification election should not have proceeded because of the pendency of a formal charge alleging a company-initiated, dominated, or supported union filed with the Bureau of Labor Relations (referenced NLRC Case No. 00-07-02466-87) [8].
- Petitioner further contended that no certification election was held in the regional offices of SSS on October 11, 1991, which resulted in an incomplete certification election and rendered void the proclamation of ACCESS as winner.
Legal Issues Presented to the Court
- Whether the Supreme Court should grant certiorari to annul the BLR orders in light of alleged administrative errors and factual issues raised by SSSEA.
- Whether SSSEA exhausted administrative remedies prior to seeking judicial relief.
- Whether issues raised by SSSEA, including the pendency of a formal charge and the alleged non-holding of elections in re