GR 194709; (July, 2013) (Digest)
G.R. No. 194709 ; July 31, 2013
MINETTE BAPTISTA, BANNIE EDSEL SAN MIGUEL, and MA. FEDAYON, Petitioners, vs. ROSARIO VILLANUEVA, et al., Respondents.
FACTS
Petitioners were members of the Radio Philippines Network Employees Union (RPNEU). They filed an impeachment complaint against their union president and later against all union officers before the DOLE, alongside petitions for an audit of union funds, based on suspicions of mismanagement. Subsequently, union members filed internal complaints against petitioners for violating the union’s Constitution and By-Laws, specifically for forming a union outside the allowed period and for initiating external actions without exhausting internal union remedies. After proceedings by the union’s Committee on Grievance and Investigation, the RPNEU Board of Directors expelled petitioners from the union.
Invoking the union security clause in their Collective Bargaining Agreement (CBA), which mandated that termination from union membership results in termination from employment, the union informed the company of the expulsions. Consequently, the company terminated petitioners’ employment. Petitioners then filed complaints for Unfair Labor Practice (ULP) against the union officers, challenging the legality of both their expulsion and subsequent dismissal.
ISSUE
Whether the union officers committed Unfair Labor Practice under Article 249 of the Labor Code by expelling petitioners from the union, leading to their termination from employment.
RULING
The Supreme Court ruled in the negative, finding no ULP committed. The Court emphasized that a union security clause is a valid contractual stipulation, and termination pursuant to it is lawful provided the underlying union expulsion is valid. The validity of the expulsion hinges on whether the union observed due process and acted in accordance with its own constitution and by-laws.
The Court found the expulsion procedurally sound. Petitioners were duly notified of the charges, given the opportunity to answer, and afforded a hearing. Their claim of being denied the right to confront witnesses physically was not a fatal defect, as administrative due process in union proceedings does not strictly require a trial-type hearing. Substantively, the expulsion was based on petitioners’ own acts of filing external complaints and impeachment actions without first exhausting the internal grievance mechanisms expressly provided in the RPNEU Constitution and By-Laws. By bypassing these internal remedies, petitioners violated union rules, justifying the disciplinary action. Since the expulsion was valid, the company’s enforcement of the CBA’s union security clause to terminate employment was likewise valid. Consequently, the union officers’ actions did not constitute ULP, which requires proof of malicious or bad faith violation of the workers’ right to self-organization.