GR L 20448; (May, 1965) (Digest)
G.R. No. L-20448 May 25, 1965
NAPOLEON MAGALIT, ET AL., petitioners, vs. COURT OF INDUSTRIAL RELATIONS, ET AL., respondents
FACTS
Petitioners Napoleon Magalit, et al., employees of the Philippine Charity Sweepstakes Office (PCSO), filed an unfair labor practice complaint with the Court of Industrial Relations (CIR) against respondents Geronimo Quadra, et al. The charge alleged that the respondents, being supervisors, violated the Magna Carta of Labor by joining a union composed exclusively of rank-and-file employees. The CIR prosecutor filed a formal complaint. Respondents denied the charge, claiming it was an election gimmick to discredit them in the upcoming PCSO Employees Association elections, and counterclaimed for damages. The presiding judge dismissed the complaint, finding that under the PCSO charter, only the General Manager could be considered a supervisor, as the board of directors sets policy and department managers implement routinary recommendations. This decision was affirmed by the CIR en banc, with one dissent.
ISSUE
Is there any factual basis for the conclusion that respondents are not supervisors within the meaning of the Magna Carta of Labor?
RULING
No. The Supreme Court reversed the CIR decision. Applying Section 2(k) of Republic Act No. 875, a “supervisor” is defined as one with authority to effectively recommend hiring, transfer, suspension, layoff, recall, discharge, assignment, or discipline of other employees, provided such authority is not merely routinary or clerical but requires independent judgment. The Court examined the official Position Description Forms submitted by the respondents to the Wage and Position Classification Office (WAPCO), which were approved by their Department Heads and the General Manager. These forms revealed that each respondent exercised general supervision over a group of executive assistants, performed research, administrative, and technical duties, and had the power to recommend action on various operational matters. These duties required the use of independent judgment and were not merely routinary. The Court held that these functions placed the respondents within the category of supervisors. The fact that respondent Geronimo Quadra also served as a liaison officer did not strip him of his supervisory character. The Court ordered respondents to cease being members of the union and to resign from any elected offices therein.