GR 120270; (June, 1999) (Digest)
G.R. No. 120270 June 16, 1999
MANOLITO BARLES, PATRICIO ELOMINA, and JUAN SAYO, petitioners, vs. HON. BENEDICTO ERNESTO BITONIO, Director, Bureau of Labor Relations, JORESTY OQUENDO, LUIS BERNALES, J. OCENA and JUANITO RAGASA, respondents.
FACTS
Petitioners were the elected president, treasurer, and auditor of Ilaw Buklod ng Manggagawa Local Chapter No. 15. After the union’s executive board increased monthly dues, private respondents, who lost in the same election, filed a petition with the Bureau of Labor Relations (BLR) for an audit of union funds. The BLR initially ordered an audit, but the case underwent several procedural shifts. The Secretary of Labor eventually endorsed the conduct of the audit to DOLE Regional Office No. IV. Petitioners filed a petition for certiorari with the Supreme Court (G.R. No. 111671) to challenge this order, which was dismissed. The Regional Office proceeded, issuing orders for petitioners to convene a meeting and explain financial discrepancies. Petitioners appealed the Regional Director’s order to the Secretary of Labor, who endorsed the appeal to the BLR. The BLR dismissed the appeal, prompting petitioners to file the present certiorari action, arguing the BLR had no jurisdiction over the appeal.
ISSUE
Whether the Bureau of Labor Relations committed grave abuse of discretion in taking cognizance of and dismissing petitioners’ appeal from the order of the Regional Director.
RULING
The Supreme Court dismissed the petition, affirming the BLR’s resolutions. The Court held that the BLR did not commit grave abuse of discretion. The legal logic is anchored on the BLR’s statutory mandate and the principle of exhaustion of administrative remedies. Under the Administrative Code of 1987, the BLR is explicitly tasked with setting policies and procedures for the examination of financial records of labor organizations. Consequently, appeals concerning such examinations properly fall within its jurisdiction. The Court further ruled that the petitioners’ appeal to the Secretary of Labor was correctly endorsed to the BLR, as the Secretary may delegate such matters to the bureau possessing technical expertise. Moreover, the doctrine of res judicata barred the petitioners’ procedural challenges, as the Supreme Court had already dismissed with finality their prior petition (G.R. No. 111671) seeking to nullify the audit order. The Court emphasized that the audit was a straightforward matter unnecessarily prolonged by procedural maneuvers and ordered its immediate implementation.