G.R. No. 91025 - Union of Filipro Employees vs. National Labor Relations Commission

Case Summary (G.R. No. 91025)

Petitioner

The Union of Filipro Employees (UFE) is the recognized bargaining representative for the rank-and-file employees of Nestle Philippines. The UFE asserted its authority to negotiate on behalf of the employees despite being challenged following the dismissal of its officers.

Respondent

Nestle Philippines, Inc. is the private respondent in this case, which has been involved in disputes with its employees concerning collective bargaining agreements (CBAs) and allegations of unfair labor practices.

Key Dates

June 30, 1987: Expiration of the previous CBAs for Nestle's work units.
June 22, 1988: UFE filed a Notice of Strike due to a deadlock in negotiations and alleged unfair labor practices.
October 28, 1988: Labor Secretary certified the dispute to the NLRC for compulsory arbitration.
June 5, 1989: The NLRC issued a resolution regarding wage increases and benefits, while denying allegations of unfair labor practices.
August 8, 1989: NLRC denied UFE's motion for reconsideration of its earlier resolution.

Applicable Law

The legal framework is primarily based on the provisions of the Labor Code of the Philippines as amended by Republic Act 6715, particularly Articles 253 and 253-A, which govern collective bargaining agreements, their terms, and conditions.

Case Background

The disputes arose after the expiration of multiple CBAs for Nestle employees. The UFE filed a Notice of Strike when negotiations became deadlocked. The company questioned the UFE's representation, and, following a series of dismissals, a complicated relationship among various factions within the union emerged. Several groups claimed representation, leading to the issuance of guidelines by the Department of Labor discouraging management from engaging these factions directly.

Administrative Actions

The NLRC's resolution, promulgated on June 5, 1989, granted wage increases and benefits while absolving Nestle from the unfair labor practices allegations. UFE contested this resolution, highlighting perceived inadequacies and legal missteps in the NLRC’s decision-making process.

Issues Raised

UFE initially raised thirteen errors, later narrowed to six key issues for consideration:

Jurisdiction of the NLRC’s division vs. en banc decision-making.
Scope of the CBA covering only certain bargaining units.
Timing of the CBA's effectiveness upon resolution promulgation.
Denial of a contract signing bonus.
Rejection of a modified union shop security clause in the CBA.
NLRC's absolution of the company from unfair labor practices.

Jurisdictional Authority

The Court affirmed the NLRC's jurisdiction based on the rules established by R.A. 6715, allowing its divisions to adjudicate cases. The amendment repealed previous requirements mandating en banc resolutions for certified disputes, such as this case, marking a shift towards expedited resolution mechanisms.

Determination of Bargaining Units

The Court found that the NLRC acted correctly in limiting the scope of the CBA only to the Makati, Alabang, and Cabuyao units, separate from the Cebu/Davao and Cagayan de Oro units. This was aligned with the certification order from the Secretary of Labor, enforcing the need for timely resolution without compounded procedural issues from other units.

CBA Effective Date and Retroactivity

The Court recognized the NLRC's authority to declare the CBA effective from the resolution's promulgation date, rather than retroactively. Given the amendments under R.A. 6715, any agreement made beyond six months post-expiration required mutual agreement for retroactivity, thus aligning with the procedural and substantive requirements of the Labor Code.

Unfair Labor Practice Claims

The Court held that matters of unfair labor practices related to separate agreements by Nestle should be addres