National Federation of Labor v. Laguesma
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a petition for certification election filed by the Alliance of Nationalist and Genuine Labor Organization (ANGLO-KMU) among the rank and file employees of Cebu Shipyard and Engineering Work, Inc. ANGLO-KMU alleged it was a legitimate labor organization, that the company employed approximately 400 rank and file employees, that the Nagkahiusang Mamumuo sa Baradero—National Federation of Labor (NFL) was the incumbent bargaining agent, and that the petition was filed within the freedom period prior to the expiration of the existing collective bargaining agreement. 2. Procedural History: The Med-Arbiter initially ordered ANGLO-KMU to submit proof of its local's legitimacy, including a charter certificate, constitution and by-laws, a statement of officers, and books of accounts, within five days, otherwise the petition would be dismissed. The NFL, as a forced intervenor, moved to dismiss, arguing ANGLO-KMU lacked legal personality and failed to meet the 25% consent requirement, asserting that the necessary documents were submitted after the freedom period expired. The Med-Arbiter dismissed the petition, finding that the required documents were submitted after the freedom period. ANGLO-KMU appealed this decision to the Undersecretary of Labor and Employment. 3. The Petition: The National Federation of Labor (NFL) filed this petition for certiorari under Rule 65 of the Rules of Court, assailing the Resolution of the Undersecretary of Labor and Employment, Bienvenido E. Laguesma, dated August 8, 1995. The Undersecretary had set aside the Med-Arbiter's resolution and found that ANGLO-KMU had complied with registration requirements at the time of filing. The NFL argued that the Undersecretary's resolution was issued in disregard of existing laws and jurisprudence and that he gravely abused his discretion in applying certain rulings. The Supreme Court, however, focused on the procedural aspect of judicial review for decisions of the Secretary of Labor and Employment, ultimately referring the case to the Court of Appeals.
Issue(s)
Whether the Resolution of the Undersecretary of Labor and Employment dated August 8, 1995, and his Order dated September 14, 1995, were issued in disregard of existing laws and jurisprudence, and the propriety of filing a petition for certiorari under Rule 65 against decisions of the Secretary of Labor and Employment. Whether the Undersecretary gravely abused his discretion in applying the ruling in the case of Fur v. Laguesma, and the specific procedural course for petitions against the Secretary of Labor.
Ruling
The Supreme Court referred the petition for certiorari to the Court of Appeals for disposition.
Ratio Decidendi
On the propriety of filing a petition for certiorari under Rule 65 against decisions of the Secretary of Labor and Employment: The Court reiterated its pronouncements in St. Martin Funeral Homes v. National Labor Relations Commission and San Miguel Corporation v. Secretary of Labor. It affirmed that while the Labor Code may not explicitly provide for judicial review of decisions of the Secretary of Labor, the power of the courts to scrutinize such acts on questions of law and jurisdiction, particularly in cases of grave abuse of discretion, remains. The Court emphasized that the remedy of an aggrieved party is to first file a motion for reconsideration, and then seasonably file a special civil action for certiorari under Rule 65. The Court noted that the legislative intent behind the elimination of appeals from the NLRC to the Supreme Court was that certiorari under Rule 65 is the proper vehicle for judicial review. Consequently, all references to appeals from the NLRC to the Supreme Court in amended Section 9 of B.P. Blg. 129 are interpreted to mean petitions for certiorari under Rule 65. The Court further clarified that due to the concurrent original jurisdiction of the Supreme Court and the Court of Appeals in Rule 65 petitions, such petitions should be initially filed in the Court of Appeals to strictly observe the doctrine on the hierarchy of courts. On the application of the ruling in Fur v. Laguesma and the specific procedural course for petitions against the Secretary of Labor: The Court, while not ruling on the merits of the petition, took the opportunity to lay down the procedural rules for reviewing decisions of the Secretary of Labor and Employment under the Labor Code. It found that the rationale in St. Martin Funeral Homes v. NLRC applies to decisions of the Secretary of Labor as well. The Court meticulously traced the evolution of appeals from labor decisions, from appeals to the President under the original Labor Code, to the elimination of such appeals by subsequent Presidential Decrees, and the current instances where appeals lie to the Secretary of Labor. It highlighted that generally, decisions of the Secretary of Labor are final and executory. However, the Court noted specific provisions in the Labor Code and its implementing rules that allow for judicial review, particularly through a petition for certiorari. The Court concluded that it is procedurally feasible and practicable to file petitions for certiorari under Rule 65 against decisions of the Secretary of Labor initially in the Court of Appeals, emphasizing strict observance of the doctrine on the hierarchy of courts. Therefore, the Court referred the present petition to the Court of Appeals for disposition.
Main Doctrine
Petitions for certiorari under Rule 65 against decisions of the Secretary of Labor and Employment should be initially filed in the Court of Appeals in strict observance of the doctrine on the hierarchy of courts.