G.R. No. L-26736 August 18, 1972
Filoil Refinery Corporation, petitioner, vs. Filoil Supervisory & Confidential Employees Association and Court of Industrial Relations, respondents.

FACTS

Petitioner Filoil Refinery Corporation sought to dismiss a petition for certification election filed by the respondent Filoil Supervisory & Confidential Employees Association, a labor organization composed exclusively of the company’s supervisory and confidential employees. The corporation argued that supervisors, being part of management, are not “employees” entitled to bargain collectively under Republic Act No. 875 (the Industrial Peace Act), and that the inclusion of confidential employees in the same bargaining unit with supervisors was improper. The existing collective bargaining agreement with the rank-and-file union expressly excluded these supervisory and confidential employees.
The Court of Industrial Relations denied the motion to dismiss. It held that Section 3 of the Industrial Peace Act expressly grants supervisors the right to form their own separate labor organizations. The court further ruled that this statutory right to organize carries with it the correlative right to bargain collectively, as the law’s denial of the right to strike to government employees, but not to supervisors, indicated legislative intent. Regarding the bargaining unit’s composition, the court found the inclusion of the few confidential employees with the supervisors to be appropriate, given their shared identity of interest as management representatives vis-à-vis the rank and file and their small numbers.

ISSUE

Whether supervisors and confidential employees have the right to organize and bargain collectively, and whether confidential employees can be validly included in the same bargaining unit as supervisors.

RULING

The Supreme Court affirmed the orders of the Court of Industrial Relations. The right of supervisors to self-organization and collective bargaining is explicitly granted by Section 3 of the Industrial Peace Act, which states that supervisors may form separate organizations of their own. This statutory right to organize logically includes the right to bargain collectively. The law’s specific denial of the right to strike to government employees, without a similar denial for supervisors, reinforces that supervisors were intended to have the full range of organizational rights except striking.
The inclusion of confidential employees in the supervisors’ bargaining unit was also upheld. The industrial court enjoys wide discretion in determining an appropriate bargaining unit to ensure the effective exercise of collective bargaining rights. Its decision to group the few confidential employees with supervisors, given their shared role as representatives of management and their identity of interest, was neither arbitrary nor capricious. Breaking the small group into multiple tiny units, as proposed by the employer, would frustrate the law’s objective of securing to employees the full benefit of their right to collective bargaining. The industrial court’s factual finding that true executive personnel handling personnel matters were excluded from the unit was accorded respect.