G.R. Nos. 92981-83. January 9, 1992. INTERNATIONAL PHARMACEUTICALS, INC., petitioner, vs. HON. SECRETARY OF LABOR and ASSOCIATED LABOR UNION (ALU), respondents.
FACTS:

Prior to the expiration of their collective bargaining agreement, a deadlock in negotiations arose between petitioner International Pharmaceuticals, Inc. (Company) and respondent Associated Labor Union (Union). The Union filed a notice of strike and, after failed conciliation, staged a strike on August 8, 1989, paralyzing the Company’s operations. Subsequently, three separate cases were filed with the National Labor Relations Commission (NLRC) involving the same parties: a Company petition for injunction and damages concerning the picket; a Union complaint for unfair labor practice; and a Company petition to declare the strike illegal.
Considering the Company is engaged in the manufacture of drugs and pharmaceuticals—an industry indispensable to the national interest—the Secretary of Labor, invoking Article 263(g) of the Labor Code, issued an order dated September 26, 1989, assuming jurisdiction over the labor dispute (the strike notice case) and directing a return-to-work. Later, upon the Union’s motion, the Secretary issued an order dated January 31, 1990, consolidating the three pending NLRC cases with the dispute over which he had assumed jurisdiction.

ISSUE

Whether the Secretary of Labor gravely abused his discretion in ordering the consolidation of the three NLRC cases with the labor dispute over which he assumed jurisdiction under Article 263(g) of the Labor Code.

RULING

The Supreme Court ruled that the Secretary of Labor did not commit grave abuse of discretion. The legal logic is anchored on the broad grant of authority under Article 263(g) of the Labor Code, which empowers the Secretary to assume jurisdiction over a labor dispute causing or likely to cause a strike or lockout in an industry indispensable to the national interest and to decide it or refer it to a voluntary arbitrator. This power is plenary and discretionary, intended to effect a speedy and equitable settlement of the entire dispute.
The Court held that the three NLRC cases, involving issues of unfair labor practice, strike legality, and related damages, are not alien or distinct from the core bargaining deadlock that prompted the strike. They are incidental controversies arising from the same factual milieu. To exclude them from the Secretary’s assumption would sanction split jurisdiction, leading to multiplicity of suits, conflicting decisions, and protracted litigation, which is obnoxious to the orderly administration of justice. The consolidation is a valid exercise of the Secretary’s rule-making power to implement the Labor Code, as embodied in Section 6, Rule V of the Revised NLRC Rules, and is germane to the statutory objective of a comprehensive resolution. The Court emphasized that doubts in implementing labor laws should be resolved in favor of labor, promoting just, speedy, and inexpensive determination of claims.