GR 114974; (June, 2004) (Digest)
G.R. No. 114974 ; June 16, 2004
Standard Chartered Bank Employees Union (NUBE), petitioner, vs. The Honorable Ma. Nieves R. Confesor, in her capacity as Secretary of Labor and Employment; and Standard Chartered Bank, respondents.
FACTS
The Standard Chartered Bank Employees Union (Union) and Standard Chartered Bank (Bank) were renegotiating the economic provisions of their Collective Bargaining Agreement (CBA). During negotiations, the Union’s panel included Jose Umali, Jr., president of the affiliated federation. The Bank’s panel initially included lawyers but removed them upon the Union’s request. The Bank, however, requested the exclusion of Umali from the Union’s panel, which the Union refused. Negotiations reached a deadlock on key economic items like wage increases and benefits. The Union subsequently filed a notice of strike citing unfair labor practice, specifically bad faith bargaining by the Bank for its insistence on excluding Umali. The Secretary of Labor assumed jurisdiction and issued an order resolving the deadlock, which included provisions less favorable than the Union’s final offers. The Secretary found that the Bank’s request to exclude Umali did not constitute bad faith.
ISSUE
Whether the Secretary of Labor committed grave abuse of discretion in finding that the Bank did not bargain in bad faith and in resolving the economic deadlock.
RULING
The Supreme Court ruled that the Secretary of Labor did not commit grave abuse of discretion. On the issue of bad faith bargaining, the Court held that a party’s request to exclude a particular individual from the opposing negotiating panel, by itself, is not conclusive proof of bad faith. Bad faith must be determined by the overall conduct of the parties during negotiations. The record showed that the Bank participated actively in numerous meetings, made counter-proposals, and showed a willingness to reach an agreement, even after its request regarding Umali was denied. The Bank’s conduct did not exhibit a deliberate desire to evade bargaining or frustrate an agreement.
Regarding the resolution of the economic deadlock, the Court emphasized the Secretary of Labor’s wide discretion and expertise in settling labor disputes when she assumes jurisdiction under Article 263(g) of the Labor Code. This power includes the authority to determine the terms and conditions of employment to resolve the dispute. The Court found that the Secretary’s order, which considered the Bank’s financial capacity and industry standards, was a reasonable exercise of this quasi-legislative power aimed at ensuring industrial peace. The Union failed to prove that the Secretary’s factual findings and economic award were arrived at arbitrarily or capriciously. Thus, the petition was denied.