Franklin Baker Company of the Philippines v. Trajano
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the classification of certain employees within the Franklin Baker Company of the Philippines, Davao Plant. Specifically, the Franklin Baker Brotherhood Association (Technical and Office Employees)-Association of Trade Unions (ATU) filed a petition for a certification election among the office and technical employees. The petitioner company did not object to the election itself but argued that seventy-four of the approximately ninety employees in this group were managerial employees and should be excluded from the election and any resulting bargaining unit. The company presented evidence that these employees, including inspectors, foremen, and supervisors, allegedly possessed powers to lay down and execute management policies, and to hire, transfer, suspend, lay-off, recall, discharge, assign, or discipline employees, or effectively recommend such actions. 2. Procedural History: The Franklin Baker Brotherhood Association-(ATU) filed its petition for certification election on April 23, 1984. Following hearings and the submission of memoranda, the Mediator-Arbiter issued an order on September 17, 1984, granting the petition and ordering a certification election among the office and technical employees. The petitioner company appealed this order to the Bureau of Labor Relations (BLR), seeking the exclusion of the seventy-four employees identified as managerial. During the appeal, sixty-one of the involved employees filed a motion to withdraw the petition, seeking their exclusion from the bargaining unit and a declaration that they were managerial employees. On April 7, 1986, the Director of the BLR dismissed the company's appeal for lack of merit and affirmed the Mediator-Arbiter's order. The company sought reconsideration, but this was denied by the Director on June 6, 1986, who affirmed his previous order in its entirety and directed the forwarding of the case for the conduct of the certification election. 3. The Petition: The Franklin Baker Company of the Philippines filed a petition for certiorari with the Supreme Court, seeking to annul the orders of the Mediator-Arbiter and the Director of the Bureau of Labor Relations. The sole assignment of error raised is that the public respondent acted with grave abuse of discretion amounting to lack of jurisdiction by ruling that the seventy-six employees in question are not managerial employees and may participate in the certification election. The petitioner argues that this ruling is contrary to jurisprudence and the factual evidence presented, which it claims was not rebutted. The petition essentially asks the Court to determine whether these employees are indeed managerial under the Labor Code and whether the Director of the BLR abused his discretion in affirming the Mediator-Arbiter's order.
Issue(s)
Whether the 76 employees (inspectors, foremen, supervisors) are managerial employees under the Labor Code. Whether the Director of the Bureau of Labor Relations acted with grave abuse of discretion in affirming the order to include these employees in the certification election.
Ruling
The petition is DISMISSED, and the assailed resolution and orders are AFFIRMED.
Ratio Decidendi
On the issue of whether the 76 employees are managerial employees: The Court affirmed the findings of the Ministry of Labor and Employment, holding that the subject employees are not managerial. While they may have recommendatory powers, these powers are subject to evaluation, review, and final action by department heads and higher executives. The Court emphasized that the test for managerial status requires the use of independent judgment, not merely routinary or clerical functions. The employees do not participate in policy making but are given ready policies to execute, thus having little freedom of action. Their recommendatory powers, as demonstrated by the cited cases, were not effective as the ultimate power to hire, fire, or suspend rested with the plant personnel manager. On the issue of grave abuse of discretion: The Court found no basis in fact and law for the petitioner's contention that the Director acted with grave abuse of discretion. The findings of administrative agencies with expertise, like the Labor Ministry, are accorded respect and finality. Certiorari is not available in the absence of a showing of abuse or misuse of power. The Court reiterated that "grave abuse of discretion" implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, which was not demonstrated in this case. The Court found no plausible reason to disturb the findings of fact and conclusions of law of the Ministry of Labor.
Main Doctrine
Managerial employees, as defined by the Labor Code, are those vested with powers to lay down and execute management policies or effectively recommend such actions, and their recommendatory powers must involve the use of independent judgment, not merely routinary or clerical functions subject to evaluation by higher executives.