GR 87676; (December, 1989) (Digest)
G.R. No. 87676 December 20, 1989
Republic of the Philippines, represented by the National Parks Development Committee, petitioner, vs. The Hon. Court of Appeals and The National Parks Development Supervisory Association & Their Members, respondents.
FACTS
The National Parks Development Committee (NPDC) filed a complaint in the Regional Trial Court seeking to declare the strike staged by the respondent NPDC Supervisory Association as illegal and to restrain it. The NPDC argued its employees, being government employees, had no right to strike. The trial court dismissed the complaint for lack of jurisdiction, holding that an employer-employee relationship existed and the labor dispute fell under the jurisdiction of the Department of Labor and Employment (DOLE) pursuant to the Labor Code. The Court of Appeals affirmed this dismissal, prompting the NPDC to elevate the case to the Supreme Court via petition for review.
The core factual dispute centered on the NPDC’s legal character. Although it was registered with the Securities and Exchange Commission as a non-stock corporation, it was originally created by executive order. By virtue of Executive Order No. 120, it was attached to the Department of Tourism with a separate budget subject to Commission on Audit audit, and the Civil Service Commission had notified it that all personnel actions were subject to CSC rules.
ISSUE
The key issue is whether the NPDC is a government agency or a private corporation, as this determination dictates whether its employees are covered by civil service rules (and thus generally prohibited from striking) or by the Labor Code (and thus possess strike rights).
RULING
The Supreme Court granted the petition, reversing the Court of Appeals. The Court ruled that the NPDC is a government agency, not a government-owned or controlled corporation. It anchored this conclusion on its recent ruling in Perlas, Jr. vs. People, which detailed the NPDC’s creation and history via executive orders, its continued operation under the Office of the President, and its funding through direct government allotments listed in annual appropriations acts.
The legal logic is clear: since the NPDC is a government agency, its employees are civil servants governed by the Civil Service Law and regulations. While the 1987 Constitution allows government employees to organize, no statute has granted them the right to strike. Consequently, the labor dispute in this case does not fall under the jurisdiction of the DOLE and the Labor Arbiters. Instead, Section 15 of Executive Order No. 180 provides that disputes involving government employees shall be heard by the Public Sector Labor-Management Council. Therefore, the trial court and the Court of Appeals erred in ceding jurisdiction to the DOLE. The Supreme Court set aside the appellate decision and directed that the complaint be filed with the proper public sector council.