GR 127374; (January, 2002) (Digest)
G.R. No. 127374 and G.R. No. 127431; January 31, 2002
PHILIPPINE SKYLANDERS, INC., et al. vs. NATIONAL LABOR RELATIONS COMMISSION, et al.; and PHILIPPINE SKYLANDERS AND WORKERS ASSOCIATION-NCW, et al. vs. PHILIPPINE ASSOCIATION OF FREE LABOR UNIONS (PAFLU) SEPTEMBER, et al.
FACTS
The Philippine Skylanders Employees Association (PSEA), a local union affiliated with the Philippine Association of Free Labor Unions (PAFLU), won a certification election. Pending a protest from a rival union, PSEA sent PAFLU a notice of disaffiliation, citing PAFLU’s dereliction of duty, and subsequently affiliated with the National Congress of Workers (NCW), becoming PSEA-NCW. The local union’s officers remained the same. PSEA-NCW then entered into a Collective Bargaining Agreement (CBA) with Philippine Skylanders, Inc. (PSI). PAFLU, through its Secretary General Serafin Ayroso, later requested PSI to bargain, but PSI refused, citing the local union’s disaffiliation. PAFLU filed complaints for unfair labor practice against PSI, its officers, and the local union’s officers, alleging interference and refusal to bargain.
The Labor Arbiter ruled in favor of PAFLU, declaring the disaffiliation invalid and the CBA void, and found PSI and the local union officers guilty of unfair labor practice for interference, ordering them to pay damages. The National Labor Relations Commission (NLRC) affirmed this decision.
ISSUE
The primary issue is whether the Labor Arbiter had jurisdiction over the complaint for unfair labor practice, or whether the matter of the local union’s disaffiliation from its mother federation constituted an inter-union dispute beyond the Labor Arbiter’s jurisdiction.
RULING
The Supreme Court reversed the NLRC and Labor Arbiter decisions. The Court held that the complaint filed by PAFLU was essentially a dispute arising from the disaffiliation of the local union, which is classified as an inter-union or intra-union conflict. Under the Labor Code’s implementing rules, such disputes fall under the exclusive original jurisdiction of the Bureau of Labor Relations (BLR) or the Department of Labor and Employment (DOLE) Secretary, not the Labor Arbiter. The Labor Arbiter’s jurisdiction over unfair labor practice cases does not extend to resolving the validity of disaffiliation, which is a prerequisite issue in this case.
The legal logic is that the unfair labor practice charges of interference and refusal to bargain were predicated on the validity of the disaffiliation. Since the disaffiliation issue itself—a question of chartering or affiliation—is an inter-union matter, the Labor Arbiter lacked jurisdiction to rule on it. Consequently, any findings on unfair labor practice stemming from that invalid assumption were void. The Court emphasized that jurisdiction is conferred by law, and the Labor Arbiter cannot assume jurisdiction over a case that properly belongs to the BLR. The petitions were granted, and the assailed decisions were set aside.