Tabigue v. International Copra Export Corporation
REITERATIONFacts
The Antecedents: Petitioners, employees of respondent International Copra Export Corporation (INTERCO), initiated a dispute by filing a Notice of Preventive Mediation with the Department of Labor and Employment - National Conciliation and Mediation Board (NCMB) against INTERCO. The core of their complaint was the alleged violation of their Collective Bargaining Agreement (CBA) and INTERCO's failure to participate in grievance conferences. Procedural History: After failing to reach a settlement at the NCMB, the petitioners sought to elevate the case to voluntary arbitration. However, the union president informed INTERCO that the petitioners were not authorized to represent the union, leading INTERCO to move for the dismissal of the complaint due to lack of jurisdiction. The NCMB Director ultimately denied the request for voluntary arbitration, citing the lack of willingness from both parties and the union's non-authorization of the petitioners. Petitioners then filed a Petition for Review with the Court of Appeals, which dismissed the petition due to procedural infirmities, including insufficient payment of docket fees, lack of proper certification of a key document, and incomplete signatures on the verification and non-forum shopping statement. The Court of Appeals further reasoned that the NCMB is not a quasi-judicial agency and thus its decisions are not appealable under Rule 43 or Rule 65. The Petition: Petitioners seek review of the Court of Appeals' decision, arguing that their case falls within the purview of specific rules governing voluntary arbitration proceedings and that the NCMB, when exercising adjudicative powers, acts as a quasi-judicial agency whose decisions are appealable. They contend that labor cases should not be resolved on technicalities, especially when substantial employee rights are affected. The petition further argues that the right of individual employees to present grievances to their employer, as stated in Article 255 of the Labor Code, should be an exception to the union's exclusive representative role in arbitration.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review on the ground of non-payment of full docket fees, lack of proper certification, and incomplete verification. Whether the National Conciliation and Mediation Board (NCMB) is a quasi-judicial agency whose decisions are appealable to the Court of Appeals. Whether the petitioners, as individual employees, have the right to submit grievances to voluntary arbitration without the express authorization of the union.
Ruling
The petition is denied. The Court of Appeals' dismissal of the petition for review is sustained.
Ratio Decidendi
On the procedural infirmities before the Court of Appeals: The Court reiterated that Section 7 of Rule 43 of the Rules of Court provides that failure to comply with requirements regarding payment of docket fees, deposit for costs, proof of service, and contents of the petition shall be sufficient ground for dismissal. While the Court may, in the interest of justice, relax the rule on belated payment of fees, the petitioners failed to proffer any reason to justify such relaxation. Therefore, the dismissal by the appellate court on this ground alone was in order. On whether the NCMB is a quasi-judicial agency: The Court held that the NCMB cannot be considered a quasi-judicial agency. Quasi-judicial function involves the power to determine what the law is, what the legal rights of the parties are, and to adjudicate upon these rights. The functions of the NCMB, as enumerated in Section 22 of Executive Order No. 126, primarily involve mediation, conciliation, preventive mediation, and administration of the voluntary arbitration program. These functions are conciliatory and facilitative, not adjudicatory. Therefore, its decisions or resolutions are not appealable to the Court of Appeals under Rule 43. On the right to submit grievances to voluntary arbitration: The Court clarified that while Article 255 of the Labor Code grants individual employees or groups of employees the right to present grievances to their employer, this right does not extend to submitting such grievances to voluntary arbitration. The CBA provisions and jurisprudence, specifically citing Atlas Farms, Inc. v. National Labor Relations Commission, indicate that only disputes involving the union and the company shall be referred to the grievance machinery or voluntary arbitrators. Since the petitioners were not duly authorized by the union to represent it in the voluntary arbitration proceedings, they could not validly initiate such a process.
Main Doctrine
The National Conciliation and Mediation Board (NCMB) is not a quasi-judicial agency, and its decisions or resolutions facilitating settlement of labor disputes are not appealable via a petition for review under Rule 43 of the Rules of Court. Furthermore, the right of individual employees to present grievances does not extend to submitting them to voluntary arbitration without proper union authorization.