G.R. No. 122226 , March 25, 1998.
UNITED PEPSI-COLA SUPERVISORY UNION (UPSU), petitioner, vs. HON. BIENVENIDO E. LAGUESMA and PEPSI-COLA PRODUCTS, PHILIPPINES, INC., respondents.

FACTS

The case involves a separate concurring opinion by Justice Puno regarding the interpretation of Article 245 of the Labor Code in relation to Section 8, Article III of the 1987 Constitution . The opinion traces the historical development of the law concerning the right of managerial, supervisory, and rank-and-file employees to join labor organizations. It notes that the Industrial Peace Act, modeled after U.S. labor laws, initially allowed supervisors to form separate organizations and did not expressly prohibit managerial employees from joining. Philippine jurisprudence, such as in a case involving Caltex managers, recognized the right of managers to organize. This changed with the enactment of the Labor Code (P.D. 442), which prohibited both supervisory and managerial employees from joining labor organizations, a prohibition affirmed in Bulletin Publishing Corp. v. Sanchez. Subsequent amendments by R.A. 6715 restored the right of supervisory employees to form their own organizations but expressly retained the prohibition against managerial employees joining, assisting, or forming any labor organization under Article 246 (now Article 245).

ISSUE

Whether Section 8, Article III of the 1987 Constitution abrogated Article 245 of the Labor Code, which prohibits managerial employees from joining, assisting, or forming any labor organization.

RULING

No. The separate concurring opinion submits that Article 245 of the Labor Code was not repealed by Section 8, Article III of the 1987 Constitution . A textual analysis of the constitutional provision does not justify such a conclusion. The opinion cautions against relying heavily on the deliberations of the Constitutional Commission to ascertain intent, as they are of limited value and an unsafe guide compared to the clear text of the law. The historical and social significance of Article 245 in Philippine labor relations law must be considered. The prohibition is based on the rationale that managerial employees, due to their position and functions, owe loyalty to the employer and represent its interests in the collective bargaining process. Their inclusion in a union would create a conflict of interest and could lead to company domination of the union. The retention of this prohibition in the Labor Code, even after the passage of R.A. 6715 following the 1987 Constitution , indicates that the legislative intent was to maintain the distinction and ineligibility of managerial employees.