Apalisok v. Radio Philippines Network
REITERATIONFacts
The Antecedents: Marilou Guanzon Apalisok, the petitioner, was employed as Production Chief of Radio Philippines Network (RPN) Station DYKC. She received a memorandum from her superior, Station Manager George Suazo, requesting an explanation for alleged acts hostile to RPN and disrespectful behavior. Subsequently, her employment was terminated effective June 15, 1995. Procedural History: Following her termination, petitioner waived her right to the RPN grievance machinery and filed a complaint for illegal dismissal before the National Labor Relations Commission. The parties then agreed to submit the dispute to voluntary arbitration. The voluntary arbitrator ruled in favor of the petitioner, declaring the dismissal invalid and awarding separation pay, backwages, damages, and attorney's fees. The respondents moved for reconsideration, which was denied. They then filed a petition for certiorari with the Supreme Court, which was referred to the Court of Appeals. The Court of Appeals nullified the voluntary arbitration award, holding that the voluntary arbitrator lacked jurisdiction. Petitioner's motion for reconsideration of this decision was denied, leading to the present petition. The Petition: The petitioner seeks review on certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' decision and resolution. The core issues raised are whether the Voluntary Arbitrator had jurisdiction over the petitioner's complaint and whether the respondents are guilty of estoppel. Petitioner argues that Article 262 of the Labor Code, as amended, grants voluntary arbitrators jurisdiction over labor disputes upon agreement of the parties, which was evidenced by the Submission Agreement signed by both parties. She further contends that even if jurisdiction was lacking, the respondents are estopped from questioning the voluntary arbitrator's authority after voluntarily submitting to it.
Issue(s)
Whether or not the Voluntary Arbitrator had jurisdiction over petitioner's complaint. Whether or not respondents are guilty of estoppel.
Ruling
The Court of Appeals Decision of October 30, 1998, is SET ASIDE and the voluntary arbitration Award of October 18, 1995, is REINSTATED.
Ratio Decidendi
On the issue of jurisdiction: Article 262 of the Labor Code of the Philippines, as amended, clearly states that a voluntary arbitrator or panel of voluntary arbitrators, upon agreement of the parties, shall hear and decide all other labor disputes. In this case, both parties, through their respective counsels, executed a Submission Agreement to submit the issue of the validity of petitioner's dismissal to the jurisdiction of the voluntary arbitrator. This agreement unequivocally demonstrates their mutual consent to have the dispute resolved by voluntary arbitration. Therefore, the voluntary arbitrator possessed the requisite jurisdiction over the parties' controversy. The Court of Appeals erred in concluding that the petitioner's waiver of the grievance machinery meant she relinquished her right to voluntary arbitration; rather, the subsequent Submission Agreement explicitly conferred jurisdiction upon the voluntary arbitrator. The act of submitting to voluntary arbitration, evidenced by the signed agreement, supersedes any prior waiver of internal grievance procedures. On the issue of estoppel: Since the Court found that the voluntary arbitrator had jurisdiction over the parties' controversy, a discussion of the second issue, whether respondents are guilty of estoppel, is rendered unnecessary. The primary issue of jurisdiction having been resolved in favor of the petitioner, the subsequent arguments regarding estoppel become moot.
Main Doctrine
A voluntary arbitrator has jurisdiction over a labor dispute if the parties, through their counsels, execute a Submission Agreement to submit the issue to voluntary arbitration, even if the petitioner initially waived the grievance machinery provided for in the Collective Bargaining Agreement.