G.R. No. 75838. August 31, 1989.
UERM EMPLOYEES UNION-FFW, petitioner, vs. THE HONORABLE MINISTER OF LABOR AND EMPLOYMENT and the UERM MEMORIAL MEDICAL CENTER, respondents.

FACTS

The petitioner union, representing employees of UERM Memorial Medical Center, entered into a Memorandum of Agreement with management on October 18, 1984, which included a provision to reopen salary increase negotiations on May 25, 1985. Prior to this, a voluntary arbitrator had awarded a P20 monthly increase effective January 1, 1984, which was implemented. Subsequently, a bargaining deadlock over wage increases led the union to file a notice of strike and eventually stage a strike on November 6, 1985. The then Ministry of Labor and Employment, through Acting Minister Carmelo C. Noriel, assumed jurisdiction over the dispute on the same day to prevent disruption of essential hospital services. The union lifted its picket line. Following a change in government leadership, a decision dated March 18, 1986, and signed by the new Minister, Augusto S. Sanchez, surfaced. This decision granted substantial wage increases and longevity pay. Union officers obtained a copy from the Minister’s office and delivered it to UERM. However, UERM’s counsel formally requested a copy for a motion for reconsideration, noting the case records were missing. Minister Sanchez responded that the decision was “not yet official and still subject to discussion.”

ISSUE

Whether the March 18, 1986 decision of the Minister of Labor had attained finality and was thus immediately executory.

RULING

No. The Supreme Court ruled that the March 18, 1986 decision did not become final and executory. For a decision of the Minister of Labor, acting as an arbitrator in a certified or assumed dispute, to attain finality, it must be officially released and served upon the parties. The Court found that the decision was never officially released by the Minister’s office. The copy received by the union was procured informally from the Minister’s assistants, and the Minister himself explicitly informed UERM’s counsel that it was not an official release. The physical records of the case were missing, and the Minister withheld formal promulgation. The legal logic is grounded in administrative due process and the nature of arbitral awards. Finality attaches only upon official release and service, which completes the adjudicative process and allows the period for appeal or motion for reconsideration to run. Since these steps were never completed, the decision remained interlocutory. The Minister retained jurisdiction and validly issued superseding orders, ultimately reiterating the final and executory award of the voluntary arbitrator. The Court further noted that the Minister’s subsequent inhibition from the case, due to his brother joining UERM’s panel, was proper to ensure impartiality but did not retroactively validate the unreleased decision. The petition was dismissed.