GR 31727; (May, 1973) (Digest)
G.R. No. L-31727 May 30, 1973
ASSOCIATED LABOR UNION, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and GOODYEAR TEXTILE MFG. CO., respondents.
FACTS
The Associated Labor Union (ALU) sent a letter to Goodyear Textile Manufacturing Co. on October 9, 1967, requesting a conference to negotiate various terms and conditions of work, including exclusive recognition, union security, and standardization of salaries. The company refused to bargain, citing an existing collective bargaining agreement with a different union, the Goodyear Textile United Workers Organization. ALU subsequently filed a notice of strike, listing grievances such as union busting, refusal to bargain, and violation of the Minimum Wage Law. A strike commenced on October 25, 1967. Despite conciliation efforts by the Department of Labor, the parties failed to settle, with negotiations stalling on the preliminary issue of union recognition.
On January 9, 1968, the Secretary of Labor, invoking Section 16(c) of the Minimum Wage Law, endorsed the labor dispute to the Court of Industrial Relations (CIR) for compulsory arbitration. The endorsement cited the ongoing strike and the inclusion of a demand for payment of the statutory minimum wage. The case was docketed as Case No. 2518-V. Goodyear moved to dismiss, arguing the CIR lacked jurisdiction because the minimum wage issue was never genuinely raised during conciliation and was merely an afterthought to invoke the CIR’s compulsory arbitration powers. The CIR en banc dismissed the case, finding the endorsement invalid as the minimum wage issue was not a true subject of the dispute during conciliation conferences.
ISSUE
Whether the Court of Industrial Relations correctly dismissed the case for lack of jurisdiction, having found that the minimum wage issue was not a bona fide subject of the labor dispute as required for a valid endorsement under Section 16(c) of the Minimum Wage Law.
RULING
The Supreme Court reversed the CIR’s dismissal and reinstated the case. The legal logic centers on the nature of the Secretary of Labor’s certification power and the CIR’s jurisdictional scope. Under Section 16(c) of the Minimum Wage Law (Republic Act No. 602), the Secretary of Labor may certify a labor dispute to the CIR for settlement when it involves a minimum wage issue and conciliation has failed. The Court held that the CIR, upon such certification, acquires jurisdiction to settle the entire dispute, not just the wage issue. The CIR erred in delving into the propriety of the Secretary’s endorsement. The certification itself is sufficient to confer jurisdiction; the CIR cannot review whether the minimum wage demand was genuinely discussed during conciliation. That determination is left to the Secretary’s discretion. Furthermore, the Court clarified that the inclusion of a minimum wage demand, a non-negotiable statutory right, transforms the character of the dispute, bringing it within the CIR’s compulsory arbitration powers to prevent strikes over such matters. The CIR’s duty was to assume jurisdiction and decide the case on its merits, including all incidental issues like unfair labor practices and bargaining recognition, which are intertwined with the certified dispute.
