Ust Faculty Union v. University of Santo Tomas
REITERATIONFacts
The Antecedents: The University of Santo Tomas Faculty Union (USTFU) scheduled a General Assembly for October 5, 1996, including an election of officers. On October 4, 1996, a convocation was held, during which an election was conducted by a group called the Reformist Alliance, resulting in the election of Gil Gamilla and others (Gamilla Group). Members of the USTFU walked out upon learning it was an election. Two groups claimed leadership: the Gamilla Group and the incumbent Mariño Group. The Mariño Group filed a complaint for Unfair Labor Practice (ULP) against the University of Santo Tomas (UST) and a complaint to nullify the Gamilla Group's election. On December 3, 1996, UST entered into a Collective Bargaining Agreement (CBA) with the Gamilla Group. On January 27, 1997, the USTFU office was padlocked, and a security guard was posted. A med-arbiter declared the Gamilla Group's election void, which was affirmed by the Bureau of Labor Relations (BLR) and this Court in G.R. No. 131235. Procedural History: The Arbitration Branch of the National Labor Relations Commission (NLRC) dismissed the ULP complaint, finding no substantial evidence that UST was guilty of ULP. The NLRC affirmed this decision, as did the Court of Appeals (CA). The CA found that the memorandum allowing the convocation did not compel attendance, UST officials were not present at the convocation, and UST was justified in dealing with the Gamilla Group as they represented themselves as duly elected officers, especially since the election's validity was still under dispute and UST's failure to deal with the recognized union would have constituted ULP. The padlocking incident was also deemed not to be an act of ULP, as the UST official present was merely there, and the security guard's presence did not prove obstruction. The Petition: The USTFU filed a Petition for Review on Certiorari, seeking to reverse the CA's decision, arguing that the respondents were guilty of ULP.
Issue(s)
Whether the respondents are guilty of Unfair Labor Practice. Whether the Court of Appeals committed serious and reversible error in sustaining the NLRC's ruling that the respondents are not guilty of Unfair Labor Practice, specifically regarding dealing with the Gamilla Group and entering into a CBA, and padlocking the USTFU office and posting a security guard. Whether the Court of Appeals manifestly overlooked relevant facts not disputed by the parties which, if properly considered, would justify a different conclusion.
Ruling
The petition is denied. The June 14, 2007 Decision and November 26, 2007 Resolution of the CA in CA-G.R. SP No. 92236 are affirmed.
Ratio Decidendi
On the issue of Unfair Labor Practice: The Court held that the petitioner failed to present substantial evidence to prove that UST committed Unfair Labor Practice (ULP). The allegations of derogatory remarks by Atty. Legaspi were unsubstantiated, as the affidavit provided contained conclusions of law rather than facts. Regarding the convocation, the memorandum issued by UST merely allowed the faculty clubs to hold it and did not compel attendance; furthermore, UST officials did not participate in the convocation, negating any claim of connivance. The Court reiterated that the burden of proof in ULP cases lies with the party alleging it, and such allegations must be supported by substantial evidence, defined as relevant evidence that a reasonable mind might accept as adequate to support a conclusion. The petitioner failed to meet this standard. The Court consistently found that the petitioner failed to adduce substantial evidence to support its claims of ULP. The allegations were either unsubstantiated or contradicted by the evidence presented. The burden of proof rests on the petitioner, and in labor cases, substantial evidence is required. The petitioner's failure to meet this quantum of proof led to the dismissal of the complaint. On the issue of dealing with the Gamilla Group and entering into a CBA, and padlocking the USTFU office and posting a security guard: The Court found that UST was justified in dealing with the Gamilla Group, including entering into a CBA, because the Gamilla Group represented themselves as the duly elected officers of the USTFU. At the time the CBA was entered into, the ruling declaring the Gamilla Group's election void was not yet final and executory. The Court emphasized that it is not the employer's duty to inquire into the validity of a union election; such matters are intra-union controversies within the jurisdiction of the med-arbiter. UST's failure to deal with the recognized representative of the bargaining unit would have constituted ULP, thus UST acted appropriately by negotiating with the group that presented itself as the legitimate union leadership. The Court ruled that the evidence presented did not support the claim that UST aided in an unlawful act. The certification regarding the padlocking showed that a university official was merely present, and the messenger of the USTFU also participated in the padlocking without coercion. The photograph of the security guard did not prove that the guard prevented the Mariño Group from performing their duties. At the time of these events, the legitimacy of the Gamilla Group was still under dispute, and UST had no reason to doubt their representation as the legitimate officers, especially in the absence of counter-evidence from the Mariño Group. Therefore, UST's actions in support of the recognized union leadership did not constitute ULP. On the alleged overlooking of facts by the CA: The Court found that the CA did not overlook any relevant facts. The CA correctly analyzed the evidence and applied the relevant labor laws and jurisprudence. The issues raised by the petitioner were thoroughly reviewed by the labor arbiter, the NLRC, and the CA, and their findings were consistent and supported by the evidence on record. The petition for review on certiorari was therefore denied.
Main Doctrine
An employer is not guilty of Unfair Labor Practice for dealing with a labor union's officers, even if their election is later declared void, as long as the employer had no knowledge of the defect in the election at the time of the dealings and the issue of the election's validity is an intra-union controversy subject to the jurisdiction of the med-arbiter.