**Facts:**
1. **February 19, 1997:** The Supreme Court ruled that certain employees in Toyota Motor Phils. Corporation (TMPC) were supervisory based on their positions under a Single Salary Structure. TMPC later implemented a Three-Function Salary Structure for personnel.
2. **February 4, 1999:** Toyota Motor Philippines Corporation Workers’ Association (TMPCWA) filed a petition for certification election to represent rank-and-file employees at TMPC’s Sta. Rosa and Bicutan Plants.
3. **March 29, 1999:** The Med-Arbiter dismissed TMPCWA’s petition. TMPCWA appealed.
4. **June 25, 1999:** DOLE reversed the decision, ordering a certification election. TMPC’s motion for reconsideration was denied.
5. **February 15, 2000:** During pre-election proceedings, TMPCWA questioned the eligibility of 120 employees, arguing they were supervisory. Despite this, the election proceeded.
6. **March 8, 2000:** In the election:
– Bicutan Plant: 305 Yes, 302 No
– Sta. Rosa Plant: 198 Yes, 138 No
– 105 votes were challenged and not counted.
7. **Post-election:** TMPCWA asserted majority based on 503 Yes votes out of 943 valid votes. TMPC opposed, requesting the opening of 91 challenged votes which they considered valid.
8. **May 12, 2000:** The Med-Arbiter certified TMPCWA as the bargaining agent, excluding challenged votes, declaring those voters supervisory.
9. **Appeal:** TMPC appealed the Med-Arbiter’s decision, asserting grave abuse of discretion.
10. **June 21, 2000 – August 4, 2000:** The challenged employees filed a petition for declaratory relief, which was granted, declaring them rank-and-file.
11. **October 19, 2000:** DOLE reaffirmed excluding the challenged votes, declaring TMPCWA the bargaining agent.
12. **March 1, 2001 – March 28, 2001:** TMPCWA intended to strike; TMPC sought a preliminary injunction.
13. **March 16, 2001:** DOLE denied TMPC’s motion for reconsideration, ruling based on actual job functions. Entry of judgment on March 19, 2001.
14. **March 27, 2001:** TMPC filed a certiorari petition with the Court of Appeals (CA), seeking the nullification of DOLE’s resolutions and a preliminary injunction.
15. **June 29, 2001:** CA granted the preliminary injunction, preventing the enforcement of DOLE’s orders.
16. **July 27, 2001:** TMPCWA filed a certiorari petition with the Supreme Court challenging the CA’s preliminary injunction.
**Issues:**
1. **Legal Standing:** Whether TMPC, as the employer, had the standing to challenge the certification election results and the status of the challenged voters.
2. **Classification of Employees:** Determining whether the challenged voters were supervisory employees based on actual job functions or were rank-and-file employees per the Three-Function Salary Structure.
3. **Grave Abuse of Discretion:** Investigating if the CA committed grave abuse of discretion in issuing the preliminary injunction.
4. **Procedural Validity:** Assessing the appropriateness and justification of DOLE’s and CA’s procedural decisions and orders.
**Court’s Decision:**
The Supreme Court held that:
1. **Employer’s Legal Standing:** TMPC has a material interest in ensuring it negotiates only with a duly certified bargaining agent representing the appropriate unit. Therefore, TMPC had standing to contest the certification election results.
2. **Classification Basis:** The Supreme Court upheld that employee classification should be based on actual job functions, consistent with established jurisprudence. Only 18 of the challenged voters met the criteria of rank-and-file employees.
3. **Grave Abuse by CA:** The CA’s issuance of a preliminary injunction was deemed a grave abuse of discretion as it pertained to merits and core issues, prematurely adjudicating fundamental questions.
4. **Procedural Integrity:** The series of procedural follow-ups and rulings, especially the affirmation by the Supreme Court of DOLE’s last decision, underscored procedural adherence required under respective jurisdictions.
**Doctrine:**
1. **Employer as Bystander:** Typically, employers are bystanders in certification elections but can claim legal standing when their substantial interests are disturbed (e.g., ensuring bona fide bargaining units).
2. **Functional Classification:** Employee classification (rank-and-file vs. supervisory) hinges on the actual job functions regardless of titles under any salary structure.
**Class Notes:**
1. **Certification Election:** Employers generally have no locus standi, but exceptions arise if vital interests in negotiating with proper entities are implicated.
2. **Jurisdiction & Forum Shopping:** Exclusive jurisdiction in resolving the status of employees in certification elections lies with DOLE, not side-stepped by subsequent declaratory relief petitions.
3. **Equity and Injunctions:** Preliminary injunctions must preserve status quo without impinging upon merits unresolved.
4. **Grave Abuse of Discretion:** Defined as whimsically, capricious actions beyond rational legal bounds.
**Historical Background:**
The case emerged from a labor dispute viewed in the broader context of labor relations in the Philippines, balancing judicial precedents, labor rights, and equitable administration under evolving corporate structures. The case’s progression showcased legal principles in labor certifications, role of employers, and appropriate representation rights reflecting a period grappling with evolving labor statutes and organizational restructuring in the late 90s to early 2000s.
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