PALN

35. Baptista v. Villanueva

July 31, 2013 | Mendoza, J.
International Activities of Union: Prohibition and Regulation

DOCTRINE: Due process, as a constitutional precept, is satisfied when a person was notified of the charge against him
and was given an opportunity to explain or defend himself. In administrative proceedings, the filing of charges and giving
reasonable opportunity for the person so charged to answer the accusations against him constitute the minimum
requirements of due process.

CASE SUMMARY: Petitioners in this case filed against multiple officers of their Union, RPNEU with the DOLE for
impeachment. During the pendency, another group of members filed against them with their Committee on Grievance and
Investigation for violation of their CBL, which was filing with the DOLE without first exhausting internal remedies. The
Committee later submitted a recommendation for their expulsion which was affirirmed, and RPN upon learning this,
terminated them in accordance with the Union Sec. Clause (USC). The NLRC and CA held that the expulsion and
therefore the termination was valid. The SC affirmed this, first stating that there was no violation of due process because
[DOCTRINE] and that the actions of the petitioners constituted a valid ground for expulsion under their CBL, which means
they were validly terminated as well.

FACTS:
 The Petitioners, former union members of Radio Philippines Network Employees Union (RPNEU), a legitimate labor
organization and the SEBA of Radio Philippines Network (RPN) filed a complaint for impeachment of their union
president, Reynato Siozon, before the executive board of RPN.
o This was abandoned and later re-lodged, this time with the DOLE against multiple RPNEU officers for violation
of the Union’s Constitution and By-Laws (CBL).
 Months later, a different group of members filed against the Petitioners for violation of ART IX Sec. 2.2 and 2.5 of
their CBL with the union’s Committee on Grievance and Investigation.
o 2.2 – Joining or forming a union outside the sixty (60) days period
o 2.5 - urging or advocating that a member start an action in any court of justice or external investigative body
against the Union or its officer without first exhausting all internal remedies open to him or available in
accordance with the CBL
 Memorandum of Notice from the Committee set the hearing on Oct. 3, 2005
o The Petitioner’s group did not appear but through communication denied the charges against them and
contested the procedure.
o Nov. 9 – Committee submitted the recommendation for expulsion to the Board of Directors of RPNEU.
o Dec. 21 – Board Affirms the recommendation and later serves the notice of expulsion on Dec. 27
o Petitioners wrote to the Board that the expulsion was done ultra vires, because they were not afforded the
opportunity to physically be present to defend themselves, violating due process.
o RPNEU informs RPN of expulsion and terminates their employment in compliance with the Union Security
Clause (USC).

 Petitioners filed complaints for Unfair Labor Practices (ULP)

o LA – ruled in favor of petitioners, ordered reinstatement
o NLRC – vacated and set aside the LA decision and dismissed the complaint for ULP for lack of merit.
 Petitioners filed a suit calling for the impeachment of the officers and members of the Executive Board of
RPNEU without first resorting to internal remedies available under its own Constitution and By-Laws.
o CA – sustained the NLRC decision, held that termination via USC is valid and recognized under their
jurisdiction.
 Denied MR and expounded that the CBL forms a covenant between the members and its stipulations are
governing law between the parties and the dictated rules must be followed before seeking Judicial relief.
 Petitioners submit that the respondents committed ULP under Article 260 (249) (a) and (b) of the LC. They insist that
they were denied substantive and procedural due process of law when they were expelled from the RPNEU.

ISSUE: W/N – Petitioners were denied procedural and substantive due process when they were expelled from the
RPNEU – NO.

RULING:
 The primary concept of ULP is embodied in Article 247 of the LC, which provides: “ Concept of unfair labor practice and
procedure for prosecution thereof. — Unfair labor practices violate the constitutional right of workers and employees to self-
organization, are inimical to the legitimate interests of both labor and management, including their right to bargain collectively and
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otherwise deal with each other in an atmosphere of freedom and mutual respect, disrupt industrial peace and hinder the
promotion of healthy and stable labor-management relations.”
o As specified in Art. 248 and 249 of the LC, the prohibited acts must necessarily relate to the workers' right to
self-organization and to the observance of a CBA. Without said vital elements, the acts complained, although
seemingly unjust, would not constitute ULP.

 Petitioner’s claim Art. XVII, Settlement of Internal Disputes of their CBL, Sec. 2 thereof, requiring members to put
their grievance in writing to be submitted to their union president, who shall strive to have the parties settle their
differences amicably.
o Based on RPNEU's CBL, the charges against petitioners were not mere internal squabbles, but violations that
demand proper investigation because, if proven, would constitute grounds for their expulsion from the union.
As such, Art. X, Investigation Procedures and Appeal Process of RPNEU's CBL, which reads:
 SECTION 1. Charge against any member or officer of the Union shall be submitted to the Board of
Directors (BOD) in writing, which shall refer the same, if necessary, to the committee on Grievance
and Investigation….

 Any supposed procedural flaw in the proceedings before the Committee was deemed cured when petitioners were
given the opportunity to be heard. Due process, as a constitutional precept, is satisfied when a person was notified
of the charge against him and was given an opportunity to explain or defend himself. In administrative proceedings,
the filing of charges and giving reasonable opportunity for the person so charged to answer the accusations against
him constitute the minimum requirements of due process.
o The essence of due process is simply to be heard, or as applied to administrative proceedings, an opportunity
to explain one's side, or an opportunity to seek a reconsideration of the action or ruling complained of.

 Mere absence of a one-on-one confrontation between the petitioners and their complainants does not automatically
affect the validity of the proceedings before the Committee. Not all cases necessitate a trial-type hearing.
o Well-settled that workers' and employers' organizations shall have the right to draw up their constitutions and
rules to elect their representatives in full freedom, to organize their administration and activities and to
formulate their programs.
o RPNEU's CBL expressly mandate that before a party is allowed to seek the intervention of the court, it is a
pre-condition that he should have availed of all the internal remedies within the organization.
o Thus, petitioners' expulsion from the union was not a deliberate attempt to curtail or restrict their right to
organize, but was triggered by the commission of an act, expressly sanctioned by Section 2.5 of Article IX of
the union's CBL.

 Unfortunately, petitioners failed to discharge the burden required to prove the charge of ULP against the
respondents. Aside from their self-serving allegations, petitioners were not able to establish how they were
restrained or coerced by their union in a way that curtailed their right to self-organization. The records likewise failed
to sufficiently show that the respondents unduly persuaded management into discriminating against petitioners other
than to bring to its attention their expulsion from the union, which in turn, resulted in the implementation of their
CBA's union security clause.

DISPOSITION: DENIED

NOTES: I don’t know why this is here. It doesn’t have anything regarding Aliens or Foreign involvement.