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ABBOTT LABORATORIES PHILIPPINES v. ABBOTT LABORATORIES EMPLOYEES UNION

FACTS:

In this case, Abbott Laboratories Philippines, Inc. (ABBOTT) is a pharmaceutical drug manufacturer and distributor. The Abbott Laboratories Employees Union (ALEU) applied for union registration, asserting that it represented 30 rank-and-file employees in ABBOTT's manufacturing unit. The Bureau of Labor Relations approved ALEU's application and issued a Certificate of Registration. However, ABBOTT filed a petition for cancellation of ALEU's registration, claiming that the application did not meet the required standards.

The Regional Director of the Bureau of Labor Relations granted ABBOTT's petition and canceled ALEU's registration. Dissatisfied with this decision, ALEU appealed to the Bureau of Labor Relations, which subsequently overturned the Regional Director's ruling and reinstated ALEU's registration.

ABBOTT, seeking further recourse, appealed the Bureau of Labor Relations' decision to the Secretary of Labor and Employment. However, the Secretary refused to act on the appeal, reasoning that the decision of the Bureau of Labor Relations is final and executory. In response to this, ABBOTT filed a petition for certiorari and mandamus to challenge the Secretary's refusal to review the decision.

ISSUES:

  1. Whether or not the Secretary of Labor and Employment has the power to review the decisions of the Bureau of Labor Relations in cases involving cancellations of certificates of registration of labor unions.

RULING:

  1. The Supreme Court held that the Secretary of Labor and Employment does not have the power to review the decisions of the Bureau of Labor Relations in cases involving cancellations of certificates of registration of labor unions. The decision of the Bureau of Labor Relations in such cases is final and executory under the Rules and Regulations Implementing the Labor Code.

PRINCIPLES:

  • The one-bargaining unit, one-employer unit policy must not be interpreted in a manner that shall derogate the right of employees to self-organization and freedom of association as guaranteed by the Constitution and international labor standards.

  • The Secretary of Labor and Employment does not have the power to review the decisions of the Bureau of Labor Relations in cases involving cancellations of certificates of registration of labor unions.