SAN MIGUEL CORPORATION SUPERVISORS v. RABLE BIENVENIDO E. LAGUESMA

FACTS:

The petitioner union filed a petition for certification election among the supervisors and exempt employees of the San Miguel Corporation (SMC) Magnolia Poultry Plants. The Med-Arbiter initially ordered the conduct of certification among all three separate plants as one bargaining unit. Respondent SMC filed an appeal, arguing that supervisory levels 3 and above, as well as the exempt employees, should be excluded from the bargaining unit. The Undersecretary of the Department of Labor and Employment (DOLE), granted SMC's appeal and remanded the case to determine the proper classification of employees in the bargaining unit. The Undersecretary later reversed his decision and allowed the conduct of separate certification elections for supervisors ranks S1 to S4 and the exempt employees. SMC filed a motion for reconsideration, arguing that supervisory levels 3 and 4, as well as the exempt employees, are confidential employees and should not be allowed to participate in a union. The Undersecretary granted the motion and excluded these employees from the certification election. The petitioner union filed a petition for certiorari to reverse the Undersecretary's order. The issues before the Court are whether supervisory levels 3 and 4 and the exempt employees are considered confidential employees and whether the employees constitute an appropriate single bargaining unit.

(Note: The case digest only includes the facts section.)

ISSUES:

  1. Whether Supervisory employees 3 and 4 and the exempt employees of the company are considered confidential employees, hence ineligible from joining a union.

  2. If they are not confidential employees, do the employees of the three plants constitute an appropriate single bargaining unit.

RULING:

  1. The employees in question, namely, supervisory employees 3 and 4 and the exempt employees, are not considered confidential employees. While they do not possess managerial powers and prerogatives, they do not fall within the definition of confidential employees as they do not assist or act in a confidential capacity to persons who formulate, determine, and effectuate management policies in the field of labor relations. Therefore, they are not ineligible from joining a union.

  2. The employees of the three plants do constitute an appropriate single bargaining unit.

PRINCIPLES:

  • Employees who are not vested with managerial powers and prerogatives are eligible to join, assist, or form a labor organization.

  • Confidential employees are those who assist or act in a confidential capacity to persons who formulate, determine, and effectuate management policies in the field of labor relations.

  • Confidential employees may be prohibited from joining a union to avoid potential conflicts of interest and ensure loyalty to the company.