G.R. No. 201595 January 25, 2016
ALLAN M. MENDOZA, Petitioner, vs. OFFICERS OF MANILA WATER EMPLOYEES UNION (MWEU), et al., Respondents.

FACTS

Petitioner Allan Mendoza was a member of the Manila Water Employees Union (MWEU). The respondent union officers charged him with failure to pay increased union dues. After hearings, the MWEU grievance committee recommended a 30-day suspension, which the Executive Board approved. Mendoza invoked his right under the union constitution to appeal this decision to the General Membership Assembly, but the union officers denied his request, claiming the appeal period had lapsed. He faced subsequent charges for continued non-payment, resulting in another suspension and, ultimately, expulsion from the union. His repeated demands to appeal to the General Membership Assembly were ignored. His expulsion led to his disqualification as a candidate in the union election. Later, during CBA negotiations, Mendoza, having joined a different union, alleged that MWEU’s proposed CBA contained discriminatory provisions against non-members.
Mendoza filed a complaint before the Labor Arbiter for unfair labor practice, specifically for illegal expulsion from the union and for interference with the right to self-organization via the discriminatory CBA proposals. The Labor Arbiter dismissed the case for lack of jurisdiction, ruling it was an intra-union dispute cognizable by the Bureau of Labor Relations (BLR). The NLRC affirmed this dismissal. The Court of Appeals likewise dismissed Mendoza’s petition, upholding the view that the case involved internal union affairs.

ISSUE

Whether the Labor Arbiter has jurisdiction over Mendoza’s complaint for unfair labor practice arising from his expulsion from the union and the union’s subsequent acts.

RULING

Yes, the Labor Arbiter has jurisdiction. The Supreme Court clarified that jurisdiction is determined by the allegations in the complaint. Mendoza’s complaint alleged specific acts constituting unfair labor practice under Article 259 (formerly Article 248) of the Labor Code, particularly union discrimination and interference with the right to self-organization. His expulsion, allegedly effected without due process and in violation of his right to appeal under union rules, and the subsequent proposal of a CBA discriminating against non-members, are not mere internal union matters. These are acts that allegedly impair the constitutional right to self-organization, which is a condition of employment.
The Court distinguished between an intra-union dispute and an unfair labor practice. While disputes involving union membership, elections, or internal administration generally fall under the BLR, a complaint transforms into an unfair labor practice case when the acts complained of are alleged to violate the Labor Code’s provisions on workers’ rights. Since Mendoza’s complaint squarely alleged violations of Article 259, it is an unfair labor practice case over which Labor Arbiters have original and exclusive jurisdiction under Article 217(a)(1) of the Labor Code. The case was remanded to the Labor Arbiter for proper proceedings on the merits of the unfair labor practice allegations.