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ST. LUKE'S MEDICAL CENTER v. RUBEN O. TORRES

FACTS:

This case involves a labor controversy between petitioner St. Luke's Medical Center and private respondent St. Luke's Medical Center Employees Association-Alliance of Filipino Workers (SLMCEA-AFW). Secretary of Labor Ruben D. Torres issued an order requiring the parties to execute and finalize their collective bargaining agreement (CBA) for the period 1990-1993, retroactive to the expiration of the previous CBA. The parties were also instructed to incorporate the disposition on economic and non-economic issues spelled out in the order. The petitioner filed a petition challenging the order, alleging violations of their right to due process and free collective bargaining, as well as the grant of monetary awards disproportionate to the petitioner's operating income.

Prior to the expiration of the previous CBA, the AFW, the federation to which the local union SLMCEA is affiliated, was plagued by internal conflicts between its leadership factions. Amidst these conflicts, the petitioner and private respondent engaged in negotiations for the renewal of the CBA. Private respondent emerged as the certified exclusive bargaining entity for the petitioner's rank and file employees. The Secretary of Labor issued an order on economic issues, including salary increases for each year, which both parties moved for reconsideration.

Petitioner St. Luke's Medical Center Employees Association-Alliance of Filipino Workers (SLMCEA-AFW) filed a petition for certification election before the Department of Labor and Employment (DOLE), seeking to be the exclusive bargaining representative of the rank and file employees of St. Luke's Medical Center (SLMC). SLMC opposed the petition, arguing that SLMCEA-AFW did not possess the requisite majority support.

The Med-Arbiter found that SLMCEA-AFW had obtained the support of the majority of the bargaining unit employees and accordingly, certified SLMCEA-AFW as the exclusive bargaining representative of SLMC's rank and file employees. SLMC filed a motion for reconsideration, but it was denied by the Med-Arbiter. SLMC then appealed to the Secretary of Labor and Employment, but the appeal was dismissed for lack of merit.

Dissatisfied with the dismissal, SLMC filed a petition for certiorari before the Supreme Court, seeking to have the dismissal order of the Secretary of Labor and Employment set aside.

The petitioner in this case argues that the respondent's grant of retroactive effect to the enforceability of the Collective Bargaining Agreement (CBA) is violative of Article 253-A of the Labor Code. According to the petitioner, the said article states that any agreement on provisions of the CBA must be made within six months from the date of expiry, or the parties must agree on the retroactivity duration. In the event of a deadlock in renegotiation, the parties can exercise their rights under the labor code.

ISSUES:

  1. Whether or not the retroactive effect given to the enforceability of the collective bargaining agreement (CBA) violates Article 253-A of the Labor Code.

  2. Whether public respondent committed grave abuse of discretion in issuing the Order of January 28, 1991.

  3. Whether the awards granted by public respondent are unreasonable and baseless.

  4. Whether the awards were granted prematurely.

  5. Whether the local union or the national federation has the legal standing to negotiate with the petitioner.

RULING:

  1. The Court held that the retroactive effect given to the enforceability of the CBA does not violate Article 253-A of the Labor Code. While the old CBA expired on July 30, 1990, the Court reasoned that the six-month period should be computed based on calendar days, not on a month having thirty days. Thus, the questioned order issued on January 28, 1991, was within the six-month period from the expiration of the old CBA.

  2. Public respondent did not commit grave abuse of discretion in issuing the Order of January 28, 1991. The court finds that public respondent considered the parties' respective contentions and allowed them to present their evidence, thereby observing due process. The court also notes that public respondent adopted petitioner's proposals in resolving the economic issues, making the awards reasonable and not arbitrarily imposed.

  3. The awards granted by public respondent are not unreasonable and baseless. Petitioner cannot deny having made the proposals adopted by public respondent and failed to rebut private respondent's allegation that said proposals were offered as the last proposal. Any objection on this point is deemed waived.

  4. The awards were not granted prematurely. It is immaterial whether the representation issue within AFW has been resolved with finality or not, as the negotiations were conducted between petitioner and the local union SLMCEA. AFW is not the real party-in-interest to the talks, and the existence of the representation issue does not bar collective bargaining.

  5. The local union, SLMCEA, which is affiliated with the national federation AFW, possesses legal standing to negotiate with the petitioner. The local union does not lose its legal personality or independence upon affiliation with a national union or federation. The locals and the national federation retain their separate personalities. Therefore, the petitioner cannot refuse to negotiate with the local union by claiming that the representation issue lies within the national federation.

PRINCIPLES:

  • Factual findings of the labor tribunals, if supported by substantial evidence, are entitled to great weight and respect (G.R. No. 98425, December 2, 1991).

  • The computation of the six-month period for the retroactivity of a CBA should be based on calendar days, not on a month having thirty days (G.R. No. 98425, December 2, 1991).

  • The exercise of jurisdiction must not be whimsical, capricious, or arbitrary, and should observe due process. (San Sebastian College vs. Court of Appeals)

  • Awards granted in a labor dispute are deemed reasonable if they are based on the proposals made by the parties.

  • The existence of a representation issue within an organization does not bar collective bargaining between an employer and the local union affiliated to said organization.

  • A duly registered local union affiliated with a national union or federation does not lose its legal personality or independence.

  • Affiliation between local unions and a national federation is for the purpose of increasing collective bargaining power.

  • The locals remained the basic units of association, subject to the restraints imposed by the Constitution and By-Laws of the Association.

  • A party cannot invoke the jurisdiction of a court to secure affirmative relief against their opponent and later repudiate or question that same jurisdiction.