SAN MIGUEL CORPORATION v. NLRC

FACTS:

In July 1990, San Miguel Corporation (SMC) declared 55 positions as redundant and closed down some plants due to financial losses. The private respondent union filed multiple grievance cases on behalf of the retrenched employees, requesting redeployment to other divisions of the company. The grievance proceedings followed the procedures set forth in the parties' Collective Bargaining Agreement (CBA). As the proceedings progressed, most of the employees were redeployed or opted for early retirement, leaving only 17 employees at the third level of the grievance procedure.

During a meeting on October 26, 1990, SMC informed the union that if the remaining employees were not redeployed by October 30, 1990, their services would be terminated on November 2, 1990. The meeting ended abruptly when a union representative declared a deadlock. Subsequently, on November 7, 1990, the union issued a notice of strike, which SMC moved to dismiss. SMC requested compliance with the provisions of the CBA on grievance machinery, arbitration, and the no-strike clause.

ISSUES:

  1. Whether or not the dismissal of the complaint of San Miguel Corporation (SMC) seeking to dismiss the notice of strike given by the private respondent union and to compel compliance with the provisions of the Collective Bargaining Agreement (CBA) was proper.

  2. Whether or not the National Labor Relations Commission (NLRC) correctly dismissed the complaint for lack of jurisdiction.

RULING:

  1. The dismissal of the complaint by the NLRC was proper. The Court held that the complaint of SMC lacked merit as it failed to comply with the procedural requirements set forth in the CBA. The Court emphasized the importance of resolving grievances through the prescribed grievance machinery, arbitration, and the no-strike clause, as provided in the CBA.

  2. The NLRC correctly dismissed the complaint for lack of jurisdiction. The Court ruled that the complaint involved an intra-union dispute, which falls within the exclusive jurisdiction of the voluntary arbitrator or panel of voluntary arbitrators. The complaint did not involve any unfair labor practice or labor dispute between an employer and an employee, and thus, did not fall within the jurisdiction of the NLRC.

PRINCIPLES:

  • The importance of complying with the procedural requirements set forth in the Collective Bargaining Agreement (CBA) in resolving grievances.

  • The exclusive jurisdiction of the voluntary arbitrator or panel of voluntary arbitrators in resolving intra-union disputes.