G.R. No. 108475 June 9, 1997
GAMALIEL DINIO, ERNESTO MANGAHAS, EDGAR S. VINSON and PARTY FOR REFORM, petitioners, vs. HON. BIENVENIDO E. LAGUESMA, Undersecretary of the Department of Labor & Employment, THE COMMITTEE ON ELECTION, represented by DANILO PICADIZO, THE NATIONAL OFFICERS OF PCIBANK EMPLOYEES UNION, THE MEMBERS OF THE COMELEC-PCIBEU, respondents.
FACTS
The case arose from the election of officers for the PCIBank Employees Union (PCIBEU) scheduled for January 31, 1992. Two parties contested: the Party for Progress and Unity (PPU) and the petitioners’ Party for Reform (PFR). A Committee on Election (COMELEC) was formed by the PCIBEU Board of Directors. On January 29, 1992, PFR filed a petition for injunction with a prayer for a temporary restraining order (TRO) with the Bureau of Labor Relations (BLR), alleging the COMELEC was not validly constituted, failed to issue necessary guidelines, dispatched ballots without PFR’s knowledge, and that the elections would be rigged. On January 30, 1992, Med-Arbiter Paterno D. Adap granted a TRO directing the COMELEC to cease and desist from holding the election. The TRO, however, only suspended elections in Metro Manila; elections in provincial branches proceeded. The COMELEC later rescheduled the Metro Manila elections to February 28, 1992, after the 20-day lifespan of the TRO lapsed. After the elections, the winners were proclaimed. PFR filed another petition seeking to nullify the elections, arguing they were invalid as the provincial elections proceeded despite the TRO and the Manila elections were held even though the TRO had not been formally lifted. The Med-Arbiter consolidated the cases and nullified the elections, ordering new elections under BLR supervision. The COMELEC appealed. Public Respondent Undersecretary of Labor Bienvenido E. Laguesma reversed the Med-Arbiter’s decision, ruling the TRO had lapsed after 20 days, thus the subsequently held elections were valid. Petitioners sought certiorari.
ISSUE
Whether the public respondent Undersecretary of Labor committed grave abuse of discretion in ruling that the union elections conducted after the lapse of the 20-day effectivity period of the temporary restraining order were valid.
RULING
The Supreme Court dismissed the petition for certiorari. The Court held that the public respondent did not commit grave abuse of discretion. The Court ruled that a temporary restraining order issued in labor disputes, pursuant to Article 218 of the Labor Code, has a lifetime of only twenty (20) days. The TRO issued by the Med-Arbiter on January 30, 1992, therefore, became void after February 19, 1992. Consequently, the union elections held in Metro Manila on February 28, 1992, were conducted when no legal prohibition existed. The Court also noted that Department of Labor and Employment representatives certified the elections as generally clean, honest, and peaceful. The other contentions of the petitioners were deemed without merit.