G.R. Nos. 81852-53 March 5, 1993
ILAW AT BUKLOD NG MANGGAGAWA (IBM), petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER MANUEL P. ASUNCION, ABUNDIO IBASCO, ANTONIO MAGSIPOC, CARLOS VILLARANTE and BIENVENIDO RAMIREZ, respondents.

FACTS

Petitioner ILAW AT BUKLOD NG MANGGAGAWA (IBM) is the sole and exclusive bargaining representative of all daily-paid workers of the Metro Manila plants of San Miguel Corporation (SMC). On December 3, 1986, IBM and SMC entered into a Memorandum of Agreement on a Collective Bargaining Agreement (CBA). The union’s National Council held a special meeting on December 7, 1986, and passed “Resolusyon Blg. 265, Serye 1986,” which was subsequently approved by the general membership. This resolution assessed each union member P1,098.00, to be deducted from a lump sum of P10,980.00 each employee was to receive under the CBA. Private respondents protested the deduction and refused to sign the authorization slip. Consequently, petitioner passed another resolution on January 6, 1987, expelling private respondents from the union. SMC held in trust the amount pertaining to each private respondent. Private respondents filed complaints before the Arbitration Branch of the National Labor Relations Commission (NLRC) for illegal and exorbitant deduction and illegal expulsion from the union. Petitioner filed a motion to dismiss on the ground of lack of jurisdiction, which was denied by respondent Labor Arbiter Manuel Asuncion. The Labor Arbiter proceeded to take cognizance of the cases and rendered a decision finding the assessment illegal, ordering the return of the deducted amounts, and declaring the expulsion null and void. The NLRC affirmed this decision. Petitioner then filed the instant petition for certiorari.

ISSUE

Whether the National Labor Relations Commission (NLRC) and the Labor Arbiter have jurisdiction over the complaints filed by private respondents, which concern an assessment and deduction from CBA differential pay and their expulsion from the union.

RULING

The Supreme Court ruled that the NLRC and the Labor Arbiter have no jurisdiction over the cases. The complaints involve an intra-union dispute—specifically, a dispute between the labor union and its members regarding the assessment and deduction of 10% from the CBA differential pay and the subsequent expulsion of members who objected. Article 226 of the Labor Code vests original and exclusive authority on the Bureau of Labor Relations and the Labor Relations Divisions to act on all inter-union or intra-union conflicts. Therefore, the subject cases fall under the jurisdiction of the Bureau of Labor Relations, not the NLRC. The Court annulled and set aside the order, decision, and resolutions of the Labor Arbiter and NLRC, and ordered the Labor Arbiter to dismiss the cases without prejudice to private respondents filing the same with the Bureau of Labor Relations.