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CAPITOL MEDICAL CENTER v. CRESENCIANO B. TRAJANO

FACTS:

Capitol Medical Center, Inc. (petitioner) is a hospital located in Quezon City, while Capitol Medical Center Employees Association-Alliance of Filipino Workers (respondent) is a labor union representing the rank-and-file employees of the hospital. On October 2, 1997, the respondent union wrote a letter to the petitioner requesting negotiation of their Collective Bargaining Agreement (CBA). In response, the petitioner challenged the union's legitimacy and refused to bargain. Subsequently, on October 15, 1997, the petitioner filed a petition to cancel the union's certificate of registration. On October 29, 1997, the respondent filed a notice of strike, alleging unfair labor practices. Despite attempts to reach a resolution, the parties were unsuccessful, leading to the respondent staging a strike on November 28, 1997.

Afterward, on December 4, 1997, the former Labor Secretary issued an Order, wherein jurisdiction over the labor dispute was assumed, and the striking workers were ordered to return to work, with management instructed to resume normal operations. The petitioner sought reconsideration of the Order, but it was denied. Consequently, the petitioner filed a petition for certiorari with the Court of Appeals, which upheld the Orders issued by the Secretary of Labor. The petitioner's subsequent motions for reconsideration were also denied.

ISSUES:

  1. Whether or not the Secretary of the Department of Labor and Employment has the authority to order the petitioner hospital to bargain collectively with the respondent labor union.

  2. Whether or not there is grave abuse of discretion on the part of the Secretary of the Department of Labor and Employment.

RULING:

  1. The Court of Appeals held that the Secretary of the Department of Labor and Employment has the authority to order the petitioner hospital to bargain collectively with the respondent labor union. The Court cited jurisprudence stating that the authority of the Secretary of Labor to assume jurisdiction over a labor dispute includes all questions and controversies arising from it. Thus, the Court found no grave abuse of discretion on the part of the Secretary.

  2. The Court of Appeals also held that there was no grave abuse of discretion on the part of the Secretary of the Department of Labor and Employment. The Court stated that the Secretary was merely following a directive previously laid down by the Supreme Court. The dismissal of the petition for cancellation of the respondent union's certificate of registration by the regional director and the affirmance of the said decision by the Director of the Bureau of Labor Relations further supported the Court's ruling.

PRINCIPLES:

  • The authority of the Secretary of Labor to assume jurisdiction over a labor dispute includes all questions and controversies arising from it.

  • The power of the Secretary of Labor is plenary and discretionary in nature to effectively and efficiently dispose of a labor dispute.

  • The Secretary of Labor's power to order collective bargaining is aimed at ending a labor dispute.