GR 151379; (January, 2005) (Digest)
G.R. No. 151379 ; January 14, 2005
University of Immaculate Concepcion, Inc., petitioner, vs. The Honorable Secretary of Labor, The UIC Teaching and Non-Teaching Personnel and Employees Union, et al., respondents.
FACTS
This case originated from a labor dispute between the University of Immaculate Concepcion (UIC) and its certified bargaining agent, the UIC Union. A panel of voluntary arbitrators ruled that certain confidential employees, including guidance counselors, secretaries, and registrars, were excluded from the bargaining unit. Subsequently, the Union filed a notice of strike. During the cooling-off period, the Secretary of Labor assumed jurisdiction over the dispute and issued a return-to-work order. After the arbitrators’ decision became final, UIC terminated the employment of the excluded confidential employees for refusing to discontinue their Union membership. The Union filed another strike notice, alleging the terminations violated the Secretary’s return-to-work order.
ISSUE
Whether the Secretary of Labor, after assuming jurisdiction over a labor dispute, can legally order the reinstatement of employees terminated by the employer, even if those employees were validly excluded from the bargaining unit as confidential employees.
RULING
Yes. The Supreme Court upheld the Secretary of Labor’s order for reinstatement. The legal logic rests on the expansive authority granted to the Secretary under Article 263(g) of the Labor Code when assuming jurisdiction over a labor dispute in an industry indispensable to the national interest. This assumption of jurisdiction carries with it the power to issue all necessary orders, including reinstatement, to restore and maintain the status quo ante and prevent the exacerbation of the dispute. The termination of the confidential employees, occurring after the Secretary’s assumption of jurisdiction and during the pendency of the dispute, was a disruptive act that threatened industrial peace. The Court clarified that the arbitrators’ decision on the employees’ exclusion from the bargaining unit pertained solely to their right to unionize. It did not authorize their dismissal. Their right to security of tenure remains separate and intact. The Secretary’s reinstatement order was a valid exercise of coercive power to enforce the return-to-work directive and preserve the status quo while the main dispute was being resolved, thereby ensuring the swift restoration of normal operations in the educational institution.