National Mines v. Luna
REITERATIONFacts
The Antecedents: The case involves a dispute between two labor unions, National Mines and Allied Workers Union (NAMAWU-MIF) and Benguet Exploration Miners' Union, concerning representation for collective bargaining. A previous case, Benguet Exploration Miners' Union v. Noriel (G.R. No. L-44110), involving the same parties and respondent Med-Arbiter, had established the policy of the Supreme Court requiring a certification election as the best means to ascertain the collective bargaining representative. Procedural History: In the previous case (G.R. No. L-44110), the Supreme Court implicitly ruled that there was no further obstacle to a certification election being held. Director Carmelo C. Noriel had previously noted that there had been no certification election for the past twelve months and no certified collective bargaining agreement, thus the petition for certification election could prosper. Despite this, respondent Med-Arbiter Erudito E. Luna issued an order dated July 29, 1977, denying the petition for certification election filed by petitioner NAMAWU-MIF. The Petition: The Med-Arbiter based his denial on the ground that the 30% signature requirement was not met, citing affidavits from employees who allegedly withdrew their support. This order was assailed by NAMAWU-MIF through a petition for certiorari and mandamus. Petitioner NAMAWU-MIF argued that the order of Med-Arbiter Luna flagrantly disregarded the principle of the 'law of the case' established in the prior Supreme Court decision (G.R. No. L-44110). They contended that the Med-Arbiter's actuation was unreasonable, capricious, and arbitrary, thus violating substantive due process. Petitioner asserted that special civil actions like certiorari and mandamus were not within the cognizance of the Bureau of Labor Relations.
Issue(s)
Whether the Med-Arbiter gravely abused his discretion amounting to lack of jurisdiction in denying the petition for certification election, thereby disregarding the principle of the 'law of the case' established by the Supreme Court. Whether the Med-Arbiter erred in disregarding the established policy of the Supreme Court favoring certification elections.
Ruling
The Supreme Court granted the petition for certiorari, nullified and set aside the order of respondent Med-Arbiter Erudito E. Luna dated July 29, 1977, and ordered that a certification election be held forthwith. The decision was declared immediately executory.
Ratio Decidendi
On the issue of the Med-Arbiter's disregard for the 'law of the case': The Court reiterated the well-known legal principle that when an appellate court has declared the law in a case, such declaration continues to be the law of that case even on subsequent appeals. This principle, known as the 'law of the case,' prevents the relitigation of issues already decided. The Court found that the Med-Arbiter's order denying the certification election directly contravened the implicit ruling in the prior case (G.R. No. L-44110) that there was no further obstacle to holding such an election. The Court emphasized that the Med-Arbiter, as a subordinate official, was bound to obey the Supreme Court's pronouncements. The attempt to dismiss the petition based on an obsolete provisional guideline was deemed a futile effort to prevent the certification election. The Court cited Zarate v. Director of Lands and People v. Olarte to underscore the finality and binding nature of the 'law of the case,' even if it were erroneous. On the issue of the Med-Arbiter's disregard for the established policy favoring certification elections: Even without relying solely on the 'law of the case' doctrine, the Court found that the Med-Arbiter's actuation was contrary to the consistent and unwavering policy of the Supreme Court requiring certification elections as the best means of ascertaining the collective bargaining representative. The Court noted that Director Noriel's earlier order, which was approved by the Court in the previous case, explicitly stated that the petition for certification election could prosper. The alleged jurisdictional bar was characterized as a flimsy pretext. The Court referenced Federacion Obrera de la Industria Tabaquera y Otros Trabajadores de Filipinas v. Noriel and Monark International, Inc. v. Noriel to highlight the liberal approach consistently followed in matters of certification elections. The Court stressed that the 30% requirement is relevant only when it becomes mandatory, and in all other instances, discretion should ordinarily be exercised in favor of a petition for certification. The Court also pointed out that the Med-Arbiter's reliance on alleged retractions of signatures was dubious, as the employees were not presented, and the best forum for determining employee allegiance is the certification election itself.
Main Doctrine
A Med-Arbiter's order denying a petition for certification election, which disregards a prior Supreme Court ruling establishing the 'law of the case' and the established policy favoring certification elections, is null and void for being violative of due process and established jurisprudence.