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SAN MIGUEL FOODS v. SAN MIGUEL CORPORATION SUPERVISORS

FACTS:

This case involves a certification election dispute between San Miguel Foods, Inc. (SMFI) and San Miguel Corporation Supervisors and Exempt Union. In a previous case, it was held that certain supervisory employees and exempt employees of SMFI are not confidential employees and are allowed to form a bargaining unit. In addition, it was determined that employees from three different plants of San Miguel Corporation Magnolia Poultry Products Plants constitute a single bargaining unit due to their community or mutuality of interests. The Department of Labor and Employment conducted pre-election conferences, but there was a disagreement regarding the list of eligible voters submitted by both parties. Subsequently, a certification election was held, and the petitioner raised objections to the eligibility of certain employees to vote. Eventually, the Med-Arbiter certified the respondent as the exclusive bargaining agent based on the election results. This decision was later affirmed with modification by the DOLE Undersecretary and the Court of Appeals. Consequently, the petitioner filed the present petition, raising various issues pertaining to the definition of the bargaining unit and the inclusion of certain positions.

ISSUES:

  1. Whether the Court of Appeals erred in expanding the scope of the bargaining unit to include employees who do not belong to or are not based in petitioner's Cabuyao or San Fernando plants.

  2. Whether the issue of union membership coverage should still be raised considering that a certification election had already taken place.

  3. Whether the position of Payroll Master should be excluded from the bargaining unit as a confidential employee.

  4. Whether or not the position of Payroll Master should be included in the bargaining unit.

  5. Whether or not the positions of Human Resource Assistant and Personnel Assistant should be excluded from the bargaining unit.

RULING:

  1. The Court affirms the finding of the Court of Appeals that there should be only one bargaining unit for the employees in Cabuyao, San Fernando, and Otis of Magnolia Poultry Products Plant involved in "dressed" chicken processing and Magnolia Poultry Farms engaged in "live" chicken operations. The Court applies the "community or mutuality of interests" test and concludes that the specific tasks of each division are interrelated, establishing a mutuality of interests that warrants the formation of a single bargaining unit.

  2. The Court rejects the argument that the issue of union membership coverage should no longer be raised because a certification election had already taken place. The Court emphasizes that the appropriateness of the bargaining unit is a significant consideration in determining the representation rights of the employees.

  3. The position of Payroll Master and other positions with access to salary and compensation data should not be excluded from the bargaining unit as confidential employees. The Court clarifies that the two criteria for a confidential employee must be met - the employee must assist or act in a confidential capacity regarding persons who formulate, determine, and effectuate management policies in the field of labor relations. The position of Payroll Master and similar positions do not meet both criteria and, therefore, should not be considered confidential employees.

  4. Yes, the position of Payroll Master should be included in the bargaining unit. The nature of their work does not involve dealing with confidential labor relations information, therefore, they cannot be excluded from the bargaining unit.

  5. Yes, the positions of Human Resource Assistant and Personnel Assistant should be excluded from the bargaining unit. Their job descriptions and access to sensitive labor relations information disqualify them from union membership.

PRINCIPLES:

  • The appropriateness of the bargaining unit is determined by the community or mutuality of interests among the employees.

  • The issue of union membership coverage remains relevant in determining representation rights despite a certification election having taken place.

  • Confidential employees are those who assist or act in a confidential capacity regarding persons who formulate, determine, and effectuate management policies in the field of labor relations. Both criteria must be met for an employee to be considered a confidential employee.

  • Article 245 of the Labor Code limits the ineligibility to join, form, and assist any labor organization to managerial employees. However, this prohibition has been extended to confidential employees or those who are required to assist or act in a fiduciary manner to managerial employees.

  • The rationale for prohibiting confidential employees from joining a labor organization is based on the potential conflict of interests and the risk of becoming a source of undue advantage. Confidential employees may compromise the loyalty and integrity of the union and may act as spies for either party to a collective bargaining agreement.

  • The doctrine of res judicata applies to decisions rendered in certification election proceedings, making the issue of which employees would constitute the bargaining unit a foregone conclusion.

  • Employers have no standing to question the process of certification elections as they should take a strict, hands-off stance. The bargaining representative of employees must owe its loyalty to the employees alone and to no other, free from any extraneous influence of management. An exception exists when the employer files the petition pursuant to Article 258 of the Labor Code due to a request to bargain collectively.