Capitol Medical Center v. Trajano
REITERATIONFacts
1. The Antecedents: Capitol Medical Center, Inc. (petitioner) refused to bargain with the Capitol Medical Center Employees Association-Alliance of Filipino Workers (respondent union), the certified collective bargaining agent of its rank-and-file employees. The petitioner challenged the union's legitimacy and filed a petition for cancellation of its registration. In response, the union filed a notice of strike, alleging unfair labor practice due to the refusal to bargain, and subsequently staged a strike. 2. Procedural History: The Secretary of Labor and Employment assumed jurisdiction over the labor dispute and ordered the striking workers to return to work and the management to resume operations. The petitioner's motion for reconsideration was denied. The petitioner then filed a petition for certiorari with the Supreme Court, which was referred to the Court of Appeals pursuant to the doctrine of hierarchy of courts. Separately, the petition to cancel the union's registration was denied by the Regional Director and affirmed by the Bureau of Labor Relations, with the denial being upheld by the Court of Appeals in another related case. The Court of Appeals ultimately affirmed the Secretary of Labor's orders, and a subsequent motion for reconsideration was denied. 3. The Petition: The petitioner seeks review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, assailing the Court of Appeals' decision and resolution. The petitioner argues that the pendency of its petition for cancellation of the respondent union's certificate of registration presented a prejudicial question that should have been resolved before the Secretary of Labor ordered collective bargaining. Additionally, the petitioner contends that the Secretary of Labor cannot exercise powers under Article 263(g) of the Labor Code without due process. The Supreme Court, however, found these arguments unmeritorious, affirming that the pendency of a cancellation proceeding does not preclude collective bargaining and that the Secretary of Labor may assume jurisdiction without prior notice or hearing.
Issue(s)
Whether the pendency of a petition for cancellation of respondent union's certificate of registration constitutes a prejudicial question that should be resolved before the Secretary of Labor can order collective bargaining. Whether the Secretary of Labor and Employment can exercise his powers under Article 263(g) of the Labor Code without observing the requirements of due process, and whether the respondent union had lost its legitimacy.
Ruling
The petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of prejudicial question: The Court held that the pendency of a petition for cancellation of union registration does not preclude collective bargaining. The Solicitor General correctly argued that if a certification election may be ordered despite a pending cancellation proceeding, then collective bargaining should also continue. The majority status of the respondent union was not affected by the pending petition, and unless its certificate of registration and status as certified bargaining agent were revoked, the hospital was legally bound to bargain collectively. The Court noted that the Supreme Court itself had previously ordered the hospital to collectively bargain with the union. On the issue of due process and legitimacy of the union: The Court reiterated that the Secretary of Labor and Employment may assume jurisdiction over a labor dispute causing or likely to cause a strike in an industry indispensable to the national interest without prior notice or hearing. This discretion is plenary and can be exercised based on the Secretary's own consideration of the exigency of the situation and its relation to national interests. The Court cited Magnolia Poultry Employees Union vs. Sanchez to support the principle that the discretion to assume jurisdiction may be exercised without prior notice or hearing. The Court also found that the petitioner's assertion that the respondent union had lost its legitimacy was unsubstantiated. The various labor administrative officials had consistently ruled that the respondent union was legitimate. Unless its Certificate of Registration was cancelled, the union remained the certified bargaining agent, and the hospital had the duty to enter into a collective bargaining agreement with it.
Main Doctrine
The pendency of a petition for cancellation of a union's certificate of registration does not preclude the employer from engaging in collective bargaining negotiations, as the union retains its status as the certified bargaining agent unless its registration is formally revoked. Furthermore, the Secretary of Labor and Employment may assume jurisdiction over a labor dispute causing or likely to cause a strike in an industry indispensable to the national interest without prior notice or hearing, as the authority under Article 263(g) of the Labor Code is plenary and discretionary.