GR 146291; (January, 2002) (Digest)
G.R. No. 146291; January 23, 2002
University of the Immaculate Concepcion, Inc., petitioner, vs. The Hon. Secretary of Labor and Employment, University of the Immaculate Concepcion Teaching and Non-Teaching Employees Union-FFW, respondents.
FACTS
Petitioner University of the Immaculate Concepcion (UIC) and respondent Union engaged in collective bargaining negotiations. During conciliation conferences at the National Conciliation and Mediation Board (NCMB) in July 1994, the parties reached agreements on several economic and non-economic issues, settling the Union’s first notice of strike. They also agreed to submit the issue of excluding certain confidential employees from the bargaining unit to voluntary arbitration, which resulted in a decision in November 1994. Subsequently, the University presented a draft CBA to the Union.
The Union rejected the draft, contending that the manner of computing the net incremental proceeds from tuition fee increases—a critical component of the agreed economic package—remained unresolved. The University insisted the Union was bound to sign the draft as it purportedly embodied all prior agreements. This impasse led the Union to file a second notice of strike in December 1994, citing bargaining deadlock and unfair labor practices. The Union eventually staged a strike on January 20, 1995. The Secretary of Labor assumed jurisdiction over the dispute.
ISSUE
Whether the Secretary of Labor correctly ruled that a bargaining deadlock still existed, justifying the Union’s strike and warranting an order for the parties to negotiate a CBA in good faith.
RULING
Yes. The Supreme Court affirmed the rulings of the Court of Appeals and the Secretary of Labor. The Court held that no final and complete Collective Bargaining Agreement had been concluded between the parties. While agreements were reached on several items during the NCMB conciliation, the minutes of those proceedings did not encompass all the terms found in the University’s subsequent draft CBA. Crucially, a major point of contention—the specific formula for computing the distribution of the incremental proceeds from tuition fee increases—was never settled. This unresolved economic issue was fundamental and prevented the execution of a final CBA.
Consequently, a bargaining deadlock legitimately persisted. The Union’s refusal to sign the draft was not a refusal to bargain in good faith but a recognition that essential terms remained open. The duty to bargain collectively continues until an agreement is reached. Therefore, the strike declared due to this deadlock was valid. The Secretary of Labor acted within his authority in assuming jurisdiction and properly directing the parties to negotiate in good faith to conclude a CBA, as the dispute constituted an industry indispensable to the national interest.