Far Eastern University-Dr. Nicanor Reyes Medical Foundation, Inc. v. Trajano
REITERATIONFacts
1. The Antecedents: The Far Eastern University-Dr. Nicanor Reyes Medical Foundation, Inc. (FEU-DRN RMF) has approximately 350 rank-and-file employees. The Alliance of Filipino Workers (AFW), a labor union, represents a majority of these employees. The core dispute revolves around the right of these employees to form and join a labor union for collective bargaining purposes. 2. Procedural History: The AFW filed a petition for certification election with the Ministry of Labor and Employment on February 13, 1986. FEU-DRN RMF opposed this petition, citing a pending Supreme Court case (G.R. No. L-49771) concerning the same parties and issues. The Med-Arbiter granted the AFW's petition on April 17, 1986, ordering a certification election. The respondent Director affirmed this order on appeal, deeming the issue moot due to the amendment of Article 244 of the Labor Code by Batas Pambansa Bilang 70, which now permits employees of non-profit medical institutions to unionize. 3. The Petition: FEU-DRN RMF filed this petition for certiorari with the Supreme Court, arguing that the respondent Director committed grave abuse of discretion by ordering a certification election while a similar case (G.R. No. L-49771) was pending before the Supreme Court. The petitioner contends that the Director improperly declared the pending case moot and academic. The Supreme Court, however, dismissed the petition, affirming the Director's decision. The Court reasoned that Batas Pambansa Bilang 70, enacted after the initial petition was filed, explicitly grants unionization rights to employees of non-profit medical institutions, rendering the prior legal challenge moot. Furthermore, the Court found that a judgment in the earlier case would not constitute res judicata in the current certification election proceedings due to the intervening amendment of the law.
Issue(s)
Whether the respondent Director gravely abused his discretion in granting the petition for certification election despite the pendency of a similar petition before the Supreme Court (G.R. No. L-49771) which involves the same parties, considering the legal basis and rights asserted in each petition. Whether employees of non-stock, non-profit medical institutions have the right to form labor unions, and the implications of Article 244 of the Labor Code as amended by Batas Pambansa Bilang 70.
Ruling
The petition is devoid of merit. The decision of the respondent Director affirming the order of the Med-Arbiter to conduct a certification election is affirmed.
Ratio Decidendi
On the pendency of a similar petition and res judicata: The Court held that the pendency of another action between the same parties for the same cause does not automatically warrant dismissal unless there is an identity of parties, rights asserted, relief prayed for, and the facts are the same, such that any judgment in the other action would constitute res judicata. In this case, the prior petition (G.R. No. L-49771) questioned the constitutionality of Article 244 of the Labor Code before its amendment. The current petition for certification election, however, invokes Article 244 as already amended by BP Blg. 70. Therefore, any judgment in the certiorari case would not constitute res judicata in the certification election case because the legal basis and the rights asserted are different. The respondent Director was not faulted for making a decision on the matter, as he had to act on the petition before him. On the right to self-organization for employees of non-stock, non-profit medical institutions: The Court affirmed that under the amended Article 244 of the Labor Code, as modified by Batas Pambansa Bilang 70, all persons employed in medical institutions, whether operating for profit or not, have the right to self-organization of their own choosing for purposes of collective bargaining. This amendment clearly grants rank and file employees of non-profit medical institutions, such as the petitioner, the right to form, organize, or join labor unions. Since the private respondent complied with the legal requisites for calling a certification election, it was incumbent upon the respondent Director to conduct such an election to determine the exclusive bargaining representative.
Main Doctrine
Employees of non-stock, non-profit medical institutions are granted the right to self-organization and to form labor unions by virtue of Batas Pambansa Bilang 70, amending Article 244 of the Labor Code. A prior petition questioning the constitutionality of the original Article 244 does not bar a subsequent petition for certification election filed after the amendment, as the legal basis and issues are distinct.