G.R. No. L-46722 June 15, 1978
NATIONAL MINES AND ALLIED WORKERS UNION (NAMAWU-MIF), petitioner, vs. ATTY. ERUDITO E. LUNA, in his capacity as Med-Arbiter, Labor Relations Division, Regional Office, Department of Labor, Baguio City; BENGUET EXPLORATION MINERS’ UNION; and BENGUET EXPLORATION, INC., respondents.

FACTS

This case involves a dispute between two labor unions, the petitioner National Mines and Allied Workers Union (NAMAWU-MIF) and the private respondent Benguet Exploration Miners’ Union, over the right to represent the employees of Benguet Exploration, Inc. The controversy is a direct sequel to a prior Supreme Court decision in Benguet Exploration Miners’ Union v. Noriel (G.R. No. L-44110). In that earlier case, the Court, upholding the policy favoring certification elections, dismissed the petition of the Benguet Exploration Miners’ Union which sought to prevent the holding of such an election. The Court’s ruling implicitly affirmed an order by Director Carmelo C. Noriel that a certification election should proceed since no election had been held in the past twelve months and no certified collective bargaining agreement existed.
Following that final decision, NAMAWU-MIF filed a petition for certification election. However, respondent Med-Arbiter Erudito E. Luna issued an order dated July 29, 1977, denying NAMAWU-MIF’s petition. He based his denial on the alleged failure of the petitioning union to meet the 30% support requirement under the Labor Code. This order effectively disregarded the prior ruling of the Supreme Court and the directive of his superior, Director Noriel, which had already cleared the way for a certification election.

ISSUE

Whether the respondent Med-Arbiter committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the petition for certification election, thereby violating the doctrine of the “law of the case” established in the prior litigation between the same parties.

RULING

Yes. The Supreme Court granted the petition and ordered the holding of a certification election. The Court ruled that the Med-Arbiter’s order constituted a grave abuse of discretion. The core of the legal logic rests on the binding doctrine of the “law of the case.” This doctrine dictates that a rule of law expressly or impliedly declared by an appellate court governs the same case in all its subsequent stages, and cannot be re-litigated or departed from by inferior courts. The prior decision in Benguet Exploration Miners’ Union v. Noriel had conclusively settled that there was no legal obstacle to conducting a certification election. By denying the petition on a new ground (the 30% requirement), the Med-Arbiter effectively reopened a matter already decided with finality by the Supreme Court. This was an impermissible defiance of a superior tribunal’s directive.
Furthermore, even without invoking this doctrine, the Med-Arbiter’s order was indefensible. The earlier order from Director Noriel, which the Supreme Court had upheld, explicitly found that the preconditions for a certification election were satisfied. The Med-Arbiter, as a subordinate, had a ministerial duty to implement that final ruling. His attempt to interpose a new jurisdictional barrier was a flimsy pretext that contravened the settled policy of the Labor Code, as consistently affirmed by the Court, to use certification elections as the most democratic method to ascertain the true bargaining representative of employees. The order was therefore issued with caprice and arbitrariness, warranting corrective action via certiorari.