Case Summary (G.R. No. 253149)
Pertinent Key Dates and Applicable Law
- Uson's acting appointment as General Manager: October 10, 2013
- Formalized appointment as General Manager: May 19, 2014, effective May 22, 2014
- PECCI Board declared appointive positions vacant including Uson's: April 17, 2017
- Uson’s complaint for illegal dismissal filed: May 30, 2017
- Cases decided by the National Labor Relations Commission (NLRC), Court of Appeals (CA), and ultimately the Supreme Court in 2023
Applicable law includes the 1987 Philippine Constitution, Republic Act No. 9520 (Philippine Cooperative Code of 2008), and Republic Act No. 11364 (Cooperative Development Authority Charter of 2019).
Factual Background
Uson had been an active member and held various positions in PECCI since 1981, including committee secretary and director, before his appointment as General Manager. His appointment was confirmed by PECCI’s Board of Directors through formal resolutions and ratified by the Cooperative Representative Assembly. In April 2017, the PECCI Board declared all appointive positions vacant, including the General Manager’s position, which led to Uson’s removal. Uson was then required to turn over cooperative properties.
Proceedings Before Labor Tribunal
Uson filed a complaint for illegal dismissal before the Labor Arbiter (LA), asserting his status as a regular employee of PECCI. The LA ruled in his favor, declaring his dismissal illegal and ordering payment for backwages and separation pay in lieu of reinstatement. Both parties separately appealed to the NLRC, which assumed jurisdiction and partially granted Uson’s appeal, further increasing the monetary award.
Ruling of the Court of Appeals
The CA reversed the NLRC ruling, holding that Uson’s dismissal was an intra-cooperative dispute that fell under the jurisdiction of the CDA. The CA determined that Uson is a cooperative officer, not merely a regular employee, and thus his dismissal should be governed by the Cooperative Code and not labor law. The CA declared the decisions of the LA and NLRC void for lack of jurisdiction and ordered Uson to return any money received pursuant to the voided rulings.
Issue Before the Supreme Court
Whether Uson’s dismissal dispute is an intra-cooperative matter exclusively within the jurisdiction of the Cooperative Development Authority or an ordinary labor dispute cognizable by the labor tribunals.
Supreme Court’s Ruling
The Supreme Court affirmed the CA’s Decision and Resolution, ruling that the dismissal of a cooperative officer is an intra-cooperative dispute under the jurisdiction of the Cooperative Development Authority pursuant to the Philippine Cooperative Code and the CDA Charter. The Court held that:
- PECCI is a duly registered cooperative governed by the Cooperative Code, which confers upon it a juridical personality and powers to manage its affairs through its board, officers, and members.
- Under the Cooperative Code, a "cooperative officer" includes the board of directors and the general manager, among others, and such officers enjoy security of tenure and can only be removed for cause after due process.
- Disputes involving cooperative officers—including their removal or dismissal—are intra-cooperative disputes that must be resolved through the mechanisms outlined in the Cooperative Code, namely, conciliation, mediation, and if those fail, voluntary arbitration before the CDA.
- The CDA Charter further empowers the CDA to hear and decide intra-cooperative disputes, with decisions appealable directly to the Court of Appeals.
- Uson was a cooperative officer because his position as General Manager was created by PECCI’s by-laws and he was appointed by the board of directors through formal resolutions. Thus, his removal is an intra-cooperative matter, not subject to the jurisdiction of the Labor Arbiter or NLRC.
- The phrase in the board resolution referring to Uson as “regular employee and simultaneous reappointment as General Manager” was interpreted to mean appointment as a full-time General Manager officer, not as an ordinary employee.
- Prior jurisprudence, including
Case Syllabus (G.R. No. 253149)
Facts of the Case
- Julius R. Uson (Uson) served as General Manager of the PLDT Employees Credit Cooperative (PECCI) until his alleged dismissal on April 21, 2017.
- Uson was an active member of the cooperative since 1981 and held various positions including committee secretary and director before his appointment as General Manager.
- PECCI is a cooperative duly registered with the Cooperative Development Authority (CDA) under Philippine laws.
- Noel P. Santos, Jesus L. Siy, Miguel B. Dawis, and Sergio P. Navarra were incumbent directors of PECCI at the time of Uson’s dismissal.
- Board Resolution dated October 10, 2013, appointed Uson as Acting General Manager until a regular appointment was made.
- On May 19, 2014, Uson’s appointment was formalized as General Manager through Board Resolution No. 6 th SB 2014-05(4)-17 which approved his regular employee status and reappointment as General Manager effective May 22, 2014.
- His tenure was ratified by PECCI’s Representative Assembly on March 28, 2015.
- On April 17, 2017, PECCI’s Board declared all appointive positions, including General Manager, vacant through Board Resolution No. 32 nd SB 2017-04 (02)-23, approved by majority incumbent directors.
- Subsequently, Uson was required to turnover all PECCI properties and was replaced by newly appointed directors.
- Aggrieved, Uson filed a Complaint for illegal dismissal with the Labor Arbiter (LA) on May 30, 2017, claiming regular employee status and entitlement to reinstatement and damages.
- PECCI asserted lack of jurisdiction on the part of labor tribunals, arguing the dismissal was an intra-cooperative dispute under the Philippine Cooperative Development Code of 2008, as amended.
Proceedings and Rulings of Labor Arbiter and NLRC
- The Labor Arbiter assumed jurisdiction and ruled in favor of Uson, finding him a regular employee illegally dismissed and awarding backwages and separation pay.
- Both parties appealed to the National Labor Relations Commission (NLRC).
- The NLRC partly granted Uson’s appeal with an increased monetary award, dismissed PECCI’s appeal, and asserted its jurisdiction over the case.
- Subsequent motions for reconsideration filed by both parties with the NLRC were denied.
Court of Appeals Decision
- The Court of Appeals (CA) consolidated the appeals and reversed the NLRC decision.
- The CA ruled the LA and NLRC lacked jurisdiction because Uson’s dismissal was an intra-cooperative dispute properly under CDA jurisdiction.
- The CA declared the earlier decisions of the labor tribunals void and ineffective.
- It ordered Uson to return any amounts received pursuant to the voided labor tribunal decisions.
- Uson’s m