San Miguel Corp. Employees Union vs.

Bersamira

Case

G.R. No. 87700

Ponente

MELENCIO-HERRERA, J

Decision Date

Jun 13, 1990

The Supreme Court ruled in favor of the Union, stating that the Regional Trial Court did not have jurisdiction over the labor
dispute between San Miguel Corporation and the San Miguel Corporation Employees Union-PTGWO, and emphasized that a
labor dispute can exist regardless of the employer-employee relationship.

Facts:

 San Miguel Corporation (SanMig) and the San Miguel Corporation Employees Union-PTGWO (the Union) had a labor
dispute over the regularization of contractual workers.

 SanMig entered into contracts with Lipercon Services, Inc. and D'Rite Service Enterprises for merchandising services.

 The contracts stated that the workers employed by these contractors were not employees or agents of SanMig.

 The Union claimed that these workers should be regularized as they had been continuously working for SanMig for a
significant period of time.

 The Union filed a notice of strike for unfair labor practice, CBA violations, and union busting.

 SanMig filed a complaint for injunction and damages to prevent the Union from representing the workers and
staging a strike.

 The Regional Trial Court issued a writ of preliminary injunction in favor of SanMig.

Issue:

 Whether the Regional Trial Court correctly assumed jurisdiction over the case and properly issued the writ of
preliminary injunction.

Ruling:

 The Supreme Court ruled in favor of the Union and set aside the orders of the Regional Trial Court.

 The Court held that the case involved a labor dispute and should have been within the jurisdiction of labor tribunals.

 The Court emphasized that a labor dispute can exist regardless of whether there is an employer-employee
relationship between the parties.

 The Union's demand for regularization and representation of the workers fell within the scope of a labor dispute.

 The case was directly connected to a labor dispute already taken cognizance of by the National Conciliation and
Mediation Board.

 Therefore, the Regional Trial Court did not have jurisdiction over the case.
Ratio:

 The Court's decision was based on the definition of a labor dispute under Article 212(1) of the Labor Code, which
includes controversies concerning the terms and conditions of employment or a change or arrangement thereof.

 The existence of an employer-employee relationship is not necessary for a labor dispute to exist.

 SanMig's argument that the case was within the jurisdiction of regular courts because it involved a claim for
damages under the Civil Code was rejected.

 The claim for damages was interwoven with the labor dispute and should be resolved through the administrative
machinery established for the settlement of labor disputes.

 The Court recognized the rights of workers to self-organization, collective bargaining, and peaceful concerted
activities, including the right to strike.

 The Court granted the writ of certiorari and prohibition, set aside the orders of the Regional Trial Court, and
enjoined the judge from taking any further action in the case except for dismissal.

 The Court ordered the observance of the status quo ante declaration of strike pending proceedings in the National
Conciliation Mediation Board.