Union of Nestle Workers Cagayan de Oro Factory v. Nestle Philippines, Inc.
REITERATIONFacts
1. The Antecedents: Nestle Philippines, Inc. (Nestle) adopted Policy No. HRM 1.8, the "Drug Abuse Policy," requiring simultaneous drug tests for all employees. In the Cagayan de Oro factory, only 28.43% of employees submitted to the test. The Union of Nestle Workers Cagayan de Oro Factory (petitioners) challenged the policy, claiming it was a subterfuge to defeat employees' constitutional rights. Nestle asserted its right to ensure employee health and to terminate those refusing the test. 2. Procedural History: Petitioners filed a complaint for injunction with a prayer for a temporary restraining order (TRO) against Nestle with the RTC. The RTC issued a TRO but later dismissed the complaint for lack of jurisdiction, opining that the case involved a labor dispute cognizable by a Voluntary Arbitrator. The RTC reasoned that while constitutional issues were raised, they were intertwined with the labor dispute concerning the implementation of a company policy. 3. The Petition: Petitioners sought a writ of certiorari from the Supreme Court, alleging grave abuse of discretion by the RTC in dismissing their complaint. The Supreme Court referred the case to the Court of Appeals (CA). The CA dismissed the petition, holding that an appeal, not certiorari, was the proper remedy against the RTC's final order, and also noted that the issue had become moot and academic as the drug testing had already been consummated. Subsequently, petitioners filed a petition for review on certiorari with the Supreme Court, raising two issues: (I) whether the RTC has jurisdiction over their suit for injunction; and (II) whether their resort to certiorari under Rule 65 was in order.
Issue(s)
Whether the Regional Trial Court has jurisdiction over petitioners’ suit for injunction. Whether petitioners’ resort to certiorari under Rule 65 is in order.
Ruling
The petition is denied. The Decision of the Court of Appeals dated December 28, 2000, and its Resolution dated April 19, 2001, are affirmed.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court: The Supreme Court held that the petitioners' insistence on the RTC's jurisdiction based on constitutional and legal issues was misplaced. The Court emphasized that jurisdiction is determined by the allegations in the complaint. The allegations in the amended complaint revealed that petitioners were assailing the manner of implementation of Nestle's Drug Abuse Policy, specifically its alleged arbitrariness due to lack of prior consultation with the union, its punitive character (suspension or dismissal for refusal), and the disregard of limitations imposed by law. The Court classified the Drug Abuse Policy as a company personnel policy, citing San Miguel Corp. vs. NLRC. Consequently, under Article 261 of the Labor Code, as amended, the original and exclusive jurisdiction to hear and decide unresolved grievances arising from the interpretation or enforcement of company personnel policies lies with the Voluntary Arbitrator or Panel of Voluntary Arbitrators, not the RTC. The RTC's dismissal for lack of jurisdiction was therefore correct. On the propriety of resorting to certiorari: The Supreme Court affirmed the CA's ruling that petitioners should have filed an appeal to the CA, not a petition for certiorari with the Supreme Court, as the assailed RTC order was final. The Court reiterated that certiorari is not a substitute for appeal. For a petition for certiorari under Rule 65 to prosper, it is not sufficient to allege grave abuse of discretion; the requirement that there is no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law must also be satisfied. Since an appeal was available to the petitioners, their resort to certiorari was improper. The Court found no exceptional circumstances to justify the deviation from the rule.
Main Doctrine
The Regional Trial Court (RTC) does not have jurisdiction over labor disputes or the interpretation and enforcement of company personnel policies, which fall under the exclusive jurisdiction of the Voluntary Arbitrator or Panel of Voluntary Arbitrators. Resort to a petition for certiorari under Rule 65 is improper when an appeal is available.