Uson v. PLDT Employees Credit Cooperative
REITERATIONFacts
The Antecedents: Petitioner Julius R. Uson (Uson) was appointed as Acting General Manager of respondent PLDT Employees Credit Cooperative (PECCI) on October 10, 2013, and subsequently as regular General Manager on May 19, 2014. His appointment was ratified by the PECCI Representative Assembly on March 28, 2015. On April 17, 2017, PECCI's Board of Directors passed a resolution declaring all appointive positions vacant, including Uson's position as General Manager. Consequently, Uson was asked to turn over PECCI properties. Procedural History: Uson filed a complaint for illegal dismissal before the Labor Arbiter (LA), praying for reinstatement with backwages and benefits, and damages. PECCI argued that the dispute was an intra-cooperative dispute within the jurisdiction of the Cooperative Development Authority (CDA). The LA ruled in favor of Uson, finding him illegally dismissed and ordering PECCI to pay separation pay and backwages. The National Labor Relations Commission (NLRC) affirmed the LA's decision, modifying the monetary award. PECCI appealed to the Court of Appeals (CA), which reversed the NLRC's decision, ruling that the LA and NLRC lacked jurisdiction and that the case was an intra-cooperative dispute. Uson's motion for reconsideration was denied. The Petition: Uson filed a Petition for Review on Certiorari before the Supreme Court, arguing that the CA erred in dismissing his petition and that the NLRC had jurisdiction over his illegal dismissal case as a regular employee.
Issue(s)
Whether the National Labor Relations Commission (NLRC) has jurisdiction over a complaint for illegal dismissal filed by a cooperative officer, considering the provisions of the Cooperative Code (Republic Act No. 9520) and the Cooperative Development Authority Charter (Republic Act No. 11364). Whether Julius R. Uson, as General Manager of PLDT Employees Credit Cooperative (PECCI), is a cooperative officer or a regular employee for purposes of determining jurisdiction, based on his appointment and the PECCI's by-laws.
Ruling
The Supreme Court denied the petition. It affirmed the Court of Appeals' ruling that the National Labor Relations Commission (NLRC) lacked jurisdiction over the complaint for illegal dismissal filed by Julius R. Uson. The Court held that Uson, as General Manager of PECCI, is a cooperative officer, and his dismissal constitutes an intra-cooperative dispute, which falls under the exclusive jurisdiction of the Cooperative Development Authority (CDA). Uson was ordered to return any amounts received from the voided judgment award.
Ratio Decidendi
On the jurisdiction of labor tribunals over disputes involving cooperative officers: The Court reiterated that a complaint for illegal dismissal filed by a cooperative officer is an intra-cooperative dispute, which is beyond the jurisdiction of labor tribunals. This is based on the provisions of the Cooperative Code (Republic Act No. 9520) and the Cooperative Development Authority Charter (Republic Act No. 11364). These laws mandate that intra-cooperative disputes must be settled through specific mechanisms, including conciliation, mediation, and voluntary arbitration, with the CDA having the ultimate authority to hear and decide such cases. The labor tribunals erroneously assumed jurisdiction, rendering their decisions void and ineffective. On the classification of Julius R. Uson as a cooperative officer: The Court found that Uson is a cooperative officer, not merely a regular employee, for the purpose of determining jurisdiction. Uson's position as General Manager was created by PECCI's by-laws, and he was appointed by the PECCI Board of Directors. The Court distinguished between a corporate/cooperative officer and an employee, stating that an officer's position is created by the charter or by-laws and is elected or appointed by the directors or stockholders, whereas an employee is typically employed by a managing officer. The phrase "hiring of [Uson] as a regular employee and simultaneous reappointment as General Manager" was interpreted to mean his appointment as a full-time General Manager, a position defined as an officer in PECCI's by-laws. Therefore, his dismissal pertains to his status as an officer, making it an intra-cooperative dispute.
Main Doctrine
A complaint for illegal dismissal filed by a cooperative officer is an intra-cooperative dispute, which falls under the exclusive jurisdiction of the Cooperative Development Authority (CDA), not the labor tribunals.