G.R. No. 180892 , April 7, 2009
UST FACULTY UNION, Petitioner, vs. UNIVERSITY OF SANTO TOMAS, REV. FR. ROLANDO DE LA ROSA, REV. FR. RODELIO ALIGAN, DOMINGO LEGASPI, and MERCEDES HINAYON, Respondents.

FACTS

On September 21, 1996, the UST Faculty Union (USTFU), then led by President Atty. Eduardo J. Mariño, Jr. (Mariño Group), informed members of a General Assembly set for October 5, 1996, which included an election of officers. On October 2, 1996, respondent Fr. Rodel Aligan issued a Memorandum granting a request from faculty clubs to hold a convocation on October 4, 1996. During this convocation, which no UST administration members attended, an election for USTFU officers was conducted by a group called the Reformist Alliance, resulting in the election of Gil Gamilla and others (Gamilla Group). Members of the incumbent USTFU walked out upon realizing an election was being held. This created two factions claiming legitimate union leadership. On October 8, 1996, the Mariño Group filed an Unfair Labor Practice (ULP) complaint against UST. On December 3, 1996, the Gamilla Group entered into a new Collective Bargaining Agreement (CBA) with UST, superseding the existing CBA. On January 27, 1997, Gamilla, accompanied by the barangay captain and UST’s Chief Security Officer, padlocked the USTFU office, after which an armed UST security guard was posted there. The Med-Arbiter and later the Bureau of Labor Relations (BLR) declared the Gamilla Group’s election null and void, a ruling ultimately upheld by the Supreme Court in a related case ( G.R. No. 131235 ) on November 16, 1999. The Labor Arbiter dismissed the ULP complaint for lack of merit, a decision affirmed by the NLRC and the Court of Appeals. The petitioner union appealed to the Supreme Court.

ISSUE

Whether the respondents (University of Santo Tomas and its officials) are guilty of Unfair Labor Practice under Article 248(a) and (d) of the Labor Code.

RULING

The Supreme Court DENIED the petition, affirming the decisions of the lower tribunals and ruling that the respondents are NOT guilty of Unfair Labor Practice. The Court held that the petitioner failed to substantiate its ULP allegations with substantial evidence. Specifically: (1) The October 2, 1996 Memorandum merely granted a request for a convocation; there was no evidence the administration attended or orchestrated the election. (2) UST’s dealings with the Gamilla Group, including entering into a CBA, were done in good faith as the Gamilla Group presented evidence of their election and the Med-Arbiter’s ruling nullifying it was not yet final at that time. (3) The padlocking of the union office and posting of a guard were actions undertaken by the Gamilla Group with barangay assistance, not initiated by UST to interfere with union affairs. The burden of proof for ULP lies with the alleging party, and the evidence presented, such as an affidavit containing a conclusion of law rather than factual specifics, was insufficient to meet the standard of substantial evidence.