MIGUEL J. VILLAOR AND CECILIO V. BAUTISTA, PETITIONERS, VS. HON. CRESENCIANO B. TRAJANO, IN HIS CAPACITY AS DIRECTOR, BUREAU OF LABOR RELATIONS OF THE MINISTRY OF LABOR AND EMPL…

Villaor versus Trajano

The Case

This is a petition for review on certiorari filed by Miguel J. Villaor and Cecilio V. Bautista against Cresenciano B. Trajano, in his capacity as Director of the Bureau of Labor Relations, together with the members of the Philippine Airlines Employees' Association Commission on Elections and the defeated candidates. The petitioners ask the Supreme Court to annul the Director's decision of November 14, 1984, which set aside the orders of the Med-Arbiter and dismissed their petition. The case matters because it fixes the boundary between union autonomy and government intervention in intra-union disputes, and because it teaches when the Bureau of Labor Relations acts with grave abuse of discretion in reversing a Med-Arbiter.

Procedural History

The dispute began before Med-Arbiter Renato D. Parungo in the Regional Office of the Ministry of Labor and Employment. The Med-Arbiter issued a writ of preliminary injunction on June 27, 1984, and an Order on August 1, 1984 disqualifying the Commission on Elections members, annulling their April 27, 1984 Resolution, voiding the May 4, 1984 special election and its results, and maintaining the injunction. The Commission members and the intervenors appealed to the Bureau of Labor Relations. Director Trajano, in a decision dated November 14, 1984, set aside both Med-Arbiter Orders and dismissed the petition for lack of merit. The petitioners then came to the Supreme Court on a petition for review on certiorari. The First Division required comments, gave due course to the petition, and directed the parties to submit memoranda. The Solicitor General filed his comment concluding that the Director committed reversible error and recommending that the petition be given due course.

Facts

The Philippine Airlines Employees' Association is the bargaining agent of the workers of Philippine Air Lines. Its Board of Directors is elected for a three-year term, and it has a Commission on Elections whose members also sit for three years. At the time, the Commission was composed of Octavio Pineda as chairman, with Rafael Samson and Edwardo Flora as members. The incumbent president and vice-president were Mario S. Santos and Carlos Bandalan.

Elections for national officers were held from February 17 to 23, 1984 in Metro Manila, and on February 20, 1984 in the Cebu and Mactan area. Miguel J. Villaor defeated Mario S. Santos for president by 1,954 votes to 1,809, a margin of 145 votes. Cecilio V. Bautista defeated Carlos Bandalan for vice-president by 1,264 votes to 1,220, a margin of 44 votes. They were proclaimed on February 25, 1984. The defeated candidates filed election protests before the union Commission on Elections, alleging that votes in certain precincts were segregated and not counted, and that members in the Cebu and Mactan area were unable to vote because the voting days were reduced from two to one. Notably, on March 6, 1984, Mario S. Santos wrote Villaor a letter formally turning over the collective bargaining proposals and wishing the officers-elect well.

On April 25, 1984, the Med-Arbiter enjoined the respondents from opening the ballot boxes, but Pineda and Samson proceeded to open them that same morning. On April 27, 1984, the Commission, without a formal hearing, set aside the proclamations, ordered the counting of segregated votes, and called a special election in Cebu and Mactan on May 4, 1984. That special election was held, and Santos and Bandalan were proclaimed on May 5, 1984. The Med-Arbiter then issued the injunction and the Order of August 1, 1984 in favor of the petitioners, which the Director reversed.

Issues

• Whether or not the decision of the Bureau of Labor Relations Director dated November 14, 1984 was promulgated with grave abuse of discretion amounting to lack of jurisdiction.

Applicable Provisions

Article 226 of the Labor Code, as cited in the decision, provides:

Article 226. Bureau of Labor Relations. The Bureau of Labor Relations and the Labor Code relations divisions of the regional offices of the Department of Labor (now the Ministry of Labor and Employment) shall have original and exclusive authority to act, at their own initiative or upon request of either or both parties, on all inter-union and intra-union conflicts and all disputes arising from or affecting labor-management relations in all workplaces whether agricultural or non-agricultural, except those arising from the implementation of collective bargaining agreements which shall be the subject of grievance procedure and/or voluntary arbitration.

This provision supplies the jurisdiction of the Med-Arbiter over the intra-union conflict, which the Director wrongly set aside.

Section 6 of Article XIX of the PALEA Constitution and By-Laws provides:

Section 6. In cases where a situation arises, whereby the losing candidate does not concede to the result of the election, he may, if he so desires, submit in writing, his protest to the Commission on Election within 30 days after the proclamation of the winning candidates and the Commission on Election, sitting en banc, shall hear and decide such protest.

This provision requires a formal hearing before the Commission resolves a protest, and conditions the right to protest on the losing candidate not having conceded the result.

Ruling

The Court resolved the sole issue in favor of the petitioners and held that the Director acted with grave abuse of discretion. On the jurisdictional question, the Court held that the freedom of unions from government interference presupposes that there is no inter-union or intra-union conflict, and here there plainly was one. The Med-Arbiter therefore rightly exercised jurisdiction. On the supposed need to exhaust administrative remedies within the union, the Court found that the petitioners had in fact exhausted them: Villaor created a Special Board of Inquiry, but the Board refused to approve it, and this claim was never denied by the private respondents.

On the protest itself, the Court applied Section 6 of Article XIX and held that once a candidate concedes the election, he is precluded from filing a protest. Mario S. Santos had already conceded the presidency to Villaor in his letter of March 6, 1984. The Court also held that the provision makes it mandatory for the Commission to set the protest for hearing before resolving it, and the Commission resolved the protest without any formal hearing. The Court further noted that Pineda and Samson intentionally disregarded the Med-Arbiter's summons and restraining order, and that the May 4, 1984 special election was without factual and legal justification, there being no law allowing piecemeal elections. On the Cebu and Mactan voting days, the Court found that a bulletin issued on February 15, 1984 announced the one-day election, so the voters were duly notified.

Doctrine

First, the Bureau of Labor Relations and the Med-Arbiters have original and exclusive authority over all inter-union and intra-union conflicts under Article 226 of the Labor Code, and union autonomy from government interference yields once an intra-union conflict arises. Second, the exhaustion of administrative remedies within the union is satisfied when the union's own Board refuses to act on the complaint. Third, under Section 6 of Article XIX of the PALEA Constitution, a losing candidate who concedes the election is precluded from filing a protest, and the Commission on Elections must hear the protest before deciding it. Fourth, piecemeal special elections held while the legality of the protest is pending are void and betray partiality.

Disposition

The Court set aside the assailed decision of the Bureau of Labor Relations Director and revived the Med-Arbiter's Orders of June 27, 1984 and August 1, 1984, so that the petitioners prevailed.

Remember This

Memorize this line: union autonomy from government interference presupposes that there is no intra-union conflict, and once one exists, the Med-Arbiter may act. Examiners use this case on the jurisdiction of Med-Arbiters over intra-union disputes, on exhaustion of union remedies, and on the requirement of a hearing in union election protests.