GR L 30632 33; (September, 1972) (Digest)
G.R. No. L-30632-33 September 28, 1972
CALTEX FILIPINO MANAGERS AND SUPERVISORS ASSOCIATION, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, CALTEX (PHILIPPINES), INC., W. E. MENEFEE and B. F. EDWARDS, respondents.
FACTS
Petitioner Caltex Filipino Managers and Supervisors Association filed a motion for reconsideration of the Supreme Court’s decision dated April 11, 1972. The core issue raised anew was whether an unfair labor practice could be committed against managerial personnel who are members of the petitioner union. The respondent company, Caltex (Philippines), Inc., defended its refusal to recognize the union by arguing it acted in good faith based on a prior Court of Industrial Relations (CIR) order. In a 1964 certification election case (Case No. 196-MC-Cebu), the CIR had declared certain positions, like Assistant Bulk Terminal Superintendent, as managerial and excluded them from a supervisory bargaining unit. The company contended that this precedent legally justified its stance that managers, being part of management, should not be included in a union with supervisors, and thus its refusal could not constitute an unfair labor practice.
ISSUE
The principal issue for resolution is whether the respondent company can be held guilty of unfair labor practice for refusing to bargain with a union that includes managerial personnel, based on its claim of a valid legal precedent.
RULING
The Supreme Court denied the motion for reconsideration, reaffirming its decision. The Court found the company’s legal basis unpersuasive. It clarified that the company’s reliance on the Supreme Court’s resolution in G.R. No. L-24212 (Caltex [Phil.], Inc. vs. Caltex Supervisors & Foremen’s Union) was misplaced. That resolution, dated March 23, 1965, merely dismissed the company’s petition for review “for lack of merit.” Such a curt dismissal did not constitute an affirmation of the CIR’s 1964 order nor establish it as a binding doctrine of law; it merely indicated the petition failed to show sufficient merit for review. Therefore, it could not serve as a valid legal shield for the company’s refusal to bargain.
The Court further rejected the blanket proposition that managerial personnel cannot be subjects of unfair labor practice. While managerial staff typically aligns with corporate interests, especially in disputes with rank-and-file employees, this does not absolutely preclude conflicts where their welfare may diverge from the concessions management is willing to grant. The right to self-organization, a constitutional guarantee, extends to all employees, and the definition of unfair labor practices under Republic Act No. 875 does not categorically exempt managerial employees. Given the factual circumstances of the case, the company’s refusal to bargain with the petitioner union, which included managers, constituted an unfair labor practice. The other grounds in the motion for reconsideration were also found to lack merit.