G.R. No. 235569. December 13, 2023
SOUTH COTABATO INTEGRATED PORT SERVICES, INC. (SCIPSI), ET AL., PETITIONERS, VS. OFFICER-IN-CHARGE ROMEO MONTEFALCO, JR., ET AL., AND MAKAR PORT LABOR ORGANIZATION (MPLO), RESPONDENTS.

FACTS

Makar Port Labor Organization (MPLO), the then-exclusive bargaining agent for SCIPSI’s rank-and-file employees, filed a petition for unfair labor practice (ULP) against SCIPSI. MPLO alleged that from August 2006 to February 2007, SCIPSI collected union dues from members via salary deduction pursuant to their Collective Bargaining Agreement (CBA) but unlawfully withheld the remittance of these collected funds. SCIPSI defended its non-remittance by arguing uncertainty over the rightful recipient due to a change in MPLO’s leadership and the dismissal of MPLO’s president, Mario Marigon, who filed the complaint. SCIPSI also raised prescription, claiming the ULP charge was filed beyond the one-year period.
The Mediator-Arbiter (Med-Arbiter) assumed jurisdiction and ordered SCIPSI to release the unremitted dues to a duly authorized MPLO representative. This order was later modified by the Bureau of Labor Relations (BLR), which directed MPLO to submit a membership list and designate a representative. The Court of Appeals upheld the Med-Arbiter’s jurisdiction, prompting SCIPSI to elevate the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Med-Arbiter had jurisdiction over the complaint for non-remittance of collected union dues, or if such complaint falls under the exclusive jurisdiction of the Labor Arbiter.

RULING

The Supreme Court ruled that the Med-Arbiter had no jurisdiction; the Labor Arbiter possesses exclusive original jurisdiction over the complaint. The Court clarified that the dispute is not an intra-union matter, which involves internal union affairs like election contests or membership issues, over which the Med-Arbiter exercises jurisdiction. Instead, the employer’s act of withholding union dues collected under a CBA check-off provision constitutes an allegation of unfair labor practice, specifically interference with the employees’ right to self-organization under Article 259 of the Labor Code.
The legal logic is grounded in the nature of the act complained of. By collecting and then refusing to remit the dues, SCIPSI, as the employer, was allegedly curtailing the union’s financial resources and operational capacity. This act of interference is a ULP charge that goes beyond mere internal union discord; it is a dispute between the bargaining agent and the employer concerning the enforcement of a CBA term and the protection of collective rights. Jurisdictional rules are strictly applied, and the characterization of the complaint’s allegations controls. Since the core allegation was ULP through interference, jurisdiction properly lies with the Labor Arbiter as provided under Article 217(a)(4) of the Labor Code. Consequently, the Court reversed the CA decision and dismissed the case without prejudice to its refiling before the proper forum.