Johnson and Johnson Labor Union-Federation of Free Workers v. Director of Labor Relations
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the petitioner-union's refusal to provide financial aid to its member, Oscar Pili, who was dismissed from his employment with Johnson & Johnson (Phil.) Inc. The union's constitution mandates financial aid of P0.75 weekly from each member to any member suspended or terminated without reasonable cause. Pili was dismissed for non-disclosure of a relative employed by the company, a violation of company policy. The union asserted that this constituted reasonable cause for termination and thus Pili was not entitled to the financial aid. 2. Procedural History: Oscar Pili filed a complaint against the petitioner-union officers for refusing to provide the mandated financial aid. Initially, a Med-Arbiter dismissed Pili's complaint. However, the Director of Labor Relations, on appeal, set aside the Med-Arbiter's order and ruled that Pili was entitled to the financial aid, contingent on his illegal dismissal case against the employer being resolved in his favor. Following motions for reconsideration, including an assertion of discrimination by Pili based on another member's case, the Director modified the decision, ordering immediate payment of the financial aid regardless of the outcome of Pili's illegal dismissal case, to avoid discriminatory treatment. The Director subsequently denied the union's motion for reconsideration and issued a writ of execution to collect the financial aid. 3. The Petition: The petitioners, Johnson and Johnson Labor Union-FFW and its members, filed this petition for review on certiorari, seeking to overturn the Director of Labor Relations' decision and subsequent orders. They argue that the decision is contrary to law, that the Director acted with grave abuse of discretion, and that union members were deprived of due process. Specifically, they contend that the union cannot be compelled to disburse funds without general membership authorization and that the Director substituted the union's decision on what constitutes reasonable cause for termination. The petition challenges the interpretation and enforcement of Article XIII, Section 5 of the union's constitution and by-laws regarding the financial aid.
Issue(s)
Whether the Director of Labor Relations committed grave abuse of discretion amounting to lack of jurisdiction in ordering the union to pay financial aid to the private respondent. Whether the union's Constitution and By-laws require individual payroll authorizations for the disbursement of financial aid, and whether the union has the prerogative to determine reasonable cause for dismissal. Whether the union members were deprived of their constitutional right to due process.
Ruling
The petition is dismissed for lack of showing of grave abuse of discretion on the part of the public respondent. The decision of the public respondent dated April 17, 1986, as modified in a resolution dated August 17, 1986, is affirmed. The temporary restraining order issued by the Court on December 24, 1986, is set aside.
Ratio Decidendi
On the issue of grave abuse of discretion and the interpretation of the union's constitution: The Court found that the Director of Labor Relations did not commit grave abuse of discretion. The provision in the union's Constitution and By-laws regarding financial aid for members terminated without reasonable cause was found to be clear and self-executory. The compulsory contributions of seventy-five centavos weekly from each member were intended for such financial aid, obviating the need for individual payroll authorizations. The Court emphasized that the union's constitution and by-laws govern the relationship between its members, and like contracts, clear terms are to be followed literally. The provision aligns with the union's aim of promoting mutual assistance among members in labor disputes. Therefore, the union could be ordered to release funds intended for mutual assistance. On whether the union's Constitution and By-laws require individual payroll authorizations for the disbursement of financial aid, and on the union's prerogative to determine reasonable cause: The Court held that while the union constitution did not explicitly state which body had the power to determine reasonable cause for dismissal, the silence on this matter implicitly recognized the labor arbiter's exclusive jurisdiction over dismissal cases. The union's constitution and by-laws are valid only insofar as they are not inconsistent with existing laws. Aggrieved members must resort to government agencies for resolution. The Court noted the conflicting interpretations by the union regarding the provision, one favoring Jerwin Taguba and another against Oscar Pili, which further supported the need for a neutral determination by a government tribunal. Quasi-judicial agencies possess expertise, and their findings of fact are accorded respect and finality if supported by substantial evidence. On the issue of due process for union members: The Court ruled that the union members were not deprived of due process because the union officers were impleaded and acted in a representative capacity for the entire membership. A suit to enforce a union constitution does not require suing each individual member, especially in a large union. The Court found that any violation of due process was more likely committed by the petitioners against the private respondent by deciding not to extend financial aid without a prior ruling from the labor arbiter on the reasonableness of his dismissal. The petitioners' remedy was to amend their constitution, not to expect the public respondent to assist in its violation.
Main Doctrine
The Director of Labor Relations did not commit grave abuse of discretion in ordering a union to provide financial aid to a dismissed member, as the union's constitution and by-laws, when clear, are self-executory and govern the relationship between the union and its members. The interpretation of such provisions, especially concerning dismissal for reasonable cause, falls within the expertise of labor tribunals.