Social Security System Employees Association v. Perlita Bathan-Velasco
REITERATIONFacts
The Antecedents: Respondent Alert and Concerned Employees for Better Social Security System (ACCESS) filed a petition for certification election among the rank and file employees of the Social Security System (SSS). The Bureau of Labor Relations (BLR) ordered the conduct of the election. Petitioner Social Security System Employees Association (SSSEA) was a contending party along with ACCESS. Procedural History: On October 11, 1991, certification elections were held where ACCESS garnered 1,378 votes, SSSEA obtained 1,116 votes, and "No Union" collected 40 votes. On October 16, 1991, SSSEA filed an election protest and/or motion to annul the certification election with the BLR, which was denied by Director Calleja on March 20, 1992. SSSEA then filed an Election Protest and/or Motion to Nullify Certification Elections in the SSS Regional Office, which was denied by respondent Velasco on November 18, 1992. Velasco declared ACCESS the winner and certified it as the sole and exclusive bargaining representative. A motion for reconsideration was denied on January 25, 1993. The Petition: SSSEA filed a special civil action for certiorari under Rule 65 of the Revised Rules of Court, seeking to annul and set aside the BLR's order dismissing the election protests.
Issue(s)
Whether the petition for certiorari was prematurely filed due to the failure to exhaust administrative remedies. Whether the issues raised by the petitioner involve factual findings that are not proper for a petition for certiorari before the Supreme Court.
Ruling
The petition is dismissed for failure to exhaust administrative remedies. No pronouncement as to costs.
Ratio Decidendi
On the failure to exhaust administrative remedies: The Court reiterated the well-entrenched rule that a party must exhaust all administrative remedies before resorting to the courts, stating that the premature invocation of the court's intervention is fatal to one's cause of action. This rule ensures that the administrative agency has an opportunity to decide the matter correctly and prevents unnecessary resort to courts. In this case, the petitioner failed to take an appeal from the order of the Director of the Bureau of Labor Relations to the Secretary of Labor, as mandated by Article 259 of the Labor Code. Absent a showing that the petitioner availed itself of the appropriate administrative remedies, the petition was dismissed for premature resort to the courts. On the nature of the issues raised: The Court noted that the issues raised by the petitioner called for a review of factual findings of the public respondent. Specifically, the petitioner argued that the certification election should not have proceeded due to a pending formal charge of a company-initiated, dominated, or supported union, and that no certification election was held in the regional offices, rendering the proclamation of ACCESS void. The Court emphasized that factual issues are not proper subjects of an original petition for certiorari before the Supreme Court, whose power of review is limited to questions of jurisdiction or grave abuse of discretion. Judicial review does not extend to an evaluation of the sufficiency of evidence upon which the proper labor officer based their determination.
Main Doctrine
A petition for certiorari will be dismissed for failure to exhaust administrative remedies, particularly by failing to appeal to the Secretary of Labor from the order of the Bureau of Labor Relations, and for raising factual issues not proper for a petition for certiorari before the Supreme Court.