San Miguel Corporation Employees Union v.

Bersamira, June
13, 1990
Doctrine: A labor dispute is “any controversy or matter concerning terms and conditions of
employment or the association or representation of persons in negotiating, fixing, maintaining,
changing, or arranging the terms and conditions of employment, regardless of whether the
disputants stand in the proximate relation of employer and employee,” which is cognizable by
the labor tribunals. Such dispute is still within the jurisdiction of labor tribunals regardless of
whether it is accompanied or linked by a case for damages.
Facts: San Miguel Corporation (SMC) hired independent contractors for merchandising services.
The contracts stipulated that the employees of the independent contractors were not to be
considered employees by SMC.
SMC executed a Collective Bargaining Agreement (CBA) with its employees, but it stated that
temporary, probationary, and contractual workers were to be excluded from the bargaining
unit.

The Union that formed out of the CBA advised SMC that some of the workers of the
independent contractors wanted to join the Union and be regularized, as some of them had
been working for SMC for a number of years, and that their work was neither casual nor
seasonal.

SMC refused, so the Union filed a notice to strike on the ground of unfair labor practice, CBA
violations, and union busting, and commenced said strike. They later filed another notice to
strike for unfair labor practice and commenced another strike. Conciliatory meetings were held,
but then after SMC filed an injunction against the strike with damages with the RTC. A motion
to dismiss was filed by the Union stating that the RTC had no jurisdiction over the dispute, but it
was denied by the RTC stating that the lack of an employer-employee relationship between the
Union and SMC negates the existence of a labor dispute.

Issue: Whether the RTC correctly assumed jurisdiction over the dispute. NO.

Ruling: The Supreme Court first defined what a labor dispute is and stated that it is “any
controversy or matter concerning terms and conditions of employment or the association or
representation of persons in negotiating, fixing, maintaining, changing, or arranging the terms
and conditions of employment, regardless of whether the disputants stand in the proximate
relation of employer and employee."
The SC then stated that what the Union sought was to regularize the status of the employees
contracted by independent contracts and, in effect, that they be absorbed into the working unit
of SMC. The Union also wanted to be able to represent the aggrieved employees. This matter,
according to the SC, dwelled on the working relationship between said employees with respect
to SMC.

SC then clarified that labor disputes are within the cognizance of the labor tribunals, as
provided by the Labor Code. SMC’s claim that this involved damages based on Art. 19-21 of the
Civil Code did not deprive the labor tribunals of this jurisdiction, as to first allow the settlement
of the case for damages, which is linked to the labor dispute, was said to result in split
jurisdiction, which was “obnoxious to the administration of justice.”

SC granted the petition.