ASSOCIATED LABOR UNIONS (ALU), PETITIONER, VS. SECRETARY OF LABOR AND STANDARD (PHIL.) FRUIT CORPORATION, RESPONDENTS.

Associated Labor Unions versus Secretary of Labor and Standard Philippines Fruit Corporation

The Case

This is a labor case in which the Associated Labor Unions, a labor union, challenged before the Supreme Court a ruling of the Secretary of Labor. The union had filed a complaint claiming additional compensation for what it called waiting or assembly time, and the Secretary of Labor dismissed that complaint. The union asked the Supreme Court to reverse the Secretary and to affirm instead the ruling of the National Labor Relations Commission, which had held that assembly time is time worked and therefore compensable working time. The case matters to a reviewee for two reasons: it shows the hierarchy of labor adjudication in operation, with the Commission and the Secretary reaching opposite conclusions on the same question, and it illustrates how a pending case may end not on the merits but by the voluntary act of the party that brought it.

Procedural History

The dispute began when the Associated Labor Unions filed a complaint for additional compensation corresponding to waiting or assembly time. The National Labor Relations Commission ruled in the union's favor, holding that assembly time is time worked and is therefore compensable working time. On appeal, the Secretary of Labor, by decision dated May 12, 1978, reversed the Commission and dismissed the union's complaint. The union then went to the Supreme Court on September 5, 1978 by a petition for certiorari, assailing the Secretary's decision and praying that the Commission's ruling be affirmed. The Supreme Court gave the petition due course, the parties filed their memoranda, and the case was submitted for decision on August 22, 1979. Before judgment could be rendered, the union filed a motion asking that its petition be considered withdrawn and the case dismissed, because the parties had entered into a compromise agreement dated September 8, 1980. One condition of that agreement was that the union withdraw its appeal, meaning its petition in this case.

Facts

The Associated Labor Unions claimed that its members were entitled to additional compensation for waiting or assembly time. The union treated that time as working time that must be paid, and it pressed the claim through the labor tribunals.

The National Labor Relations Commission agreed with the union and held that assembly time is time worked and therefore compensable. The Secretary of Labor, however, took the contrary view and dismissed the complaint in a decision dated May 12, 1978.

The union brought the matter to the Supreme Court by certiorari. While the petition was pending and after it had been submitted for decision, the parties settled their dispute. They executed a compromise agreement dated September 8, 1980, one condition of which required the union to withdraw its appeal. The union accordingly moved to withdraw its petition and have the case dismissed.

Issues

• Whether or not the petition for certiorari assailing the decision of the Secretary of Labor should be granted and the ruling of the National Labor Relations Commission affirmed.
• Whether or not the petition should be considered withdrawn and the case dismissed in view of the compromise agreement between the parties.

Applicable Provisions

The decision does not quote or construe any statutory provision. It rests entirely on the procedural effect of the parties' compromise agreement and the union's motion to withdraw its petition. No article of the Labor Code or any other statute is set out in the text, and none is supplied here.

Ruling

On the first issue, the Court never reached the merits. The question of whether assembly time is compensable working time, on which the Commission and the Secretary had parted ways, was left unresolved because the case did not proceed to judgment.

On the second issue, the Court granted the motion. The union asked that its petition be considered withdrawn and the case dismissed, and it did so because of the compromise agreement dated September 8, 1980, one condition of which was that the union withdraw its appeal in this case. The Court honored that agreement and the motion founded on it. Its dispositive language was direct:

WHEREFORE, the motion is granted. This case is dismissed and considered closed. No costs.

The Court thus gave effect to the will of the parties as embodied in their compromise, and it closed the case without costs against either side.

Doctrine

A pending case may be terminated by the voluntary act of the party who instituted it, and where the parties have entered into a compromise agreement, the Court will give effect to that agreement. Here the compromise expressly required the union to withdraw its appeal, and the Court treated the withdrawal as the operative act that ended the litigation.

When a case is dismissed on the petitioner's own motion pursuant to a compromise, the Court decides nothing on the merits. The contrasting rulings of the National Labor Relations Commission and the Secretary of Labor on whether assembly time is compensable working time therefore stand without Supreme Court resolution and carry no doctrinal weight from this decision.

A reviewee should state the rule carefully: this case is authority on the effect of a compromise and a withdrawal upon a pending petition, not on the compensability of assembly time.

Disposition

The Court granted the union's motion, dismissed the case, and considered it closed, with no costs.

Remember This

Remember the single line: a compromise agreement conditioned on the withdrawal of the appeal, once moved upon, leads the Court to dismiss the case and consider it closed, with no costs. Examiners use this case to test whether a candidate recognizes that a dismissal by compromise or withdrawal decides nothing on the merits, so the labor law question the parties fought over remains open.