Ilaw at Buklod ng Manggagawa v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner, Ilaw at Buklod ng Manggagawa (IBM), a labor union representing daily-paid workers of San Miguel Corporation (SMC), entered into a Memorandum of Agreement on Collective Bargaining Agreement (CBA) with SMC. The CBA was ratified by 2,107 out of 2,243 members present. Under the CBA, each member was to receive P10,980.00, from which P1,098.00 was assessed as a deduction. Private respondents protested this deduction and refused to sign authorization slips. Consequently, petitioner IBM passed a resolution expelling the private respondents from the union. SMC held the deducted amounts in trust. Procedural History: Private respondents filed separate complaints before the National Labor Relations Commission (NLRC) and its Arbitration Branch, alleging illegal and exorbitant deduction and illegal expulsion from the union. Petitioner IBM filed a motion to dismiss, asserting lack of jurisdiction. The Labor Arbiter denied the motion and proceeded to hear the cases, eventually rendering a decision finding the assessment illegal, ordering the return of the deducted amounts, declaring the expulsion void, and enjoining further expulsions for objecting to the deduction. The NLRC affirmed the Labor Arbiter's decision. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for certiorari seeking to annul the orders and resolutions of the Labor Arbiter and the NLRC, primarily on the ground that they gravely abused their discretion in assuming jurisdiction over the case, which petitioner contended was an intra-union dispute falling under the exclusive jurisdiction of the Bureau of Labor Relations.
Issue(s)
Whether the NLRC committed reversible error in assuming jurisdiction over the person of the petitioner union. Whether the NLRC committed reversible error in assuming jurisdiction over the nature of the action. Whether the NLRC committed reversible error in declaring the sum from which the special assessment is made is a wage, that it is a deduction from a wage, and that it is an attorney's fee.
Ruling
The petition is granted. The order dated February 4, 1987, the decision rendered on May 29, 1987, by the respondent Labor Arbiter, and the resolutions dated October 12, 1987, and January 11, 1988, of the respondent National Labor Relations Commission are ANNULLED and SET ASIDE. The Labor Arbiter is ordered to dismiss NLRC Case No. 1-072-87 and NLRC Case No. 00-02-00731-87, without prejudice to private respondents' filing the same with the Bureau of Labor Relations.
Ratio Decidendi
On the issue of jurisdiction over the person of the petitioner union: While the petition also raised the issue of jurisdiction over the person, the Court found it unnecessary to delve into this matter extensively, given its conclusion on the lack of jurisdiction over the subject matter. The primary error committed by the respondent labor officials was their assumption of jurisdiction over the nature of the dispute itself. The Court's focus remained on the statutory grant of exclusive jurisdiction to the Bureau of Labor Relations for intra-union disputes. The Court reiterated that the nature of the action, as determined by the allegations in the complaint, dictates which body has jurisdiction. Since the core of the dispute was an internal union matter, the NLRC and its Labor Arbiter could not validly exercise jurisdiction, regardless of whether the union had submitted to their authority in other respects. The Court's decision to annul the proceedings was based on the fundamental principle that a tribunal without jurisdiction cannot validly act on a case. On the issue of jurisdiction over the nature of the action: The Court held that the subject matter of the complaints, which involved an assessment and deduction of union members' CBA differential pay and their subsequent expulsion from the union, constituted an intra-union dispute. Article 226 of the Labor Code of the Philippines explicitly vests the Bureau of Labor Relations (BLR) with original and exclusive authority to act on all inter-union and intra-union conflicts. The Court emphasized that jurisdiction over the subject matter is conferred by law and is determined by the allegations in the complaint. In this case, the allegations clearly pointed to a dispute between a labor union and its members concerning internal union matters, specifically the validity of a resolution imposing an assessment and the legality of expelling members who objected to it. Therefore, the Labor Arbiter and the NLRC lacked jurisdiction to hear and decide these cases, as they fall squarely within the exclusive domain of the BLR. The Court cited Tijam vs. Sibonghanoy and Serrano vs. Muñoz (Hi) Motors, Inc. to support the principle that jurisdiction is conferred by law and determined by the allegations in the complaint. There is no ratio provided for the issue of whether the NLRC committed reversible error in declaring the sum from which the special assessment is made is a wage, that it is a deduction from a wage, and that it is an attorney's fee.
Main Doctrine
The Bureau of Labor Relations, not the Labor Arbiter or the National Labor Relations Commission, has original and exclusive jurisdiction over intra-union disputes, which include disputes arising from violations of the union's constitution and by-laws or the rights of union members, such as illegal deductions and illegal expulsion from the union.