Thursday, January 22, 2009

Abbot Laboratories Philippines Inc. v. Abbott Laboratories Employees Union [323 SCRA 392, January 26, 2000]



FACTS: Abbott Laboratories Employees union (ALEU) filed an application for union registration with DOLE. The Bureau of Labor Relations approved the petition and issued the corresponding certificate of registration, thereby transforming ALEU sought to operate, sought to cancel ALEU’s certificate of registration, on the grounds that the latter’s application was not signed by at least 20% of the rank and file employees of Abbot, and that it failed to submit copies of its books of account. Subsequently, the Regional Director of the BLR upheld the said petition and cancelled ALEU’s certificate of registration. Or appeal, the BRL reversed the judgment of the Regional Director, and upheld ALEU’s legitimacy. Abbott appealed the BLR’s decision to the Secretary of Labor. The latter refused to act on Abbott’s appeal, citing he fact that the SOLE has no jurisdiction to review the decision of the BLR on appeals in cancellation cases emanating from the BLR Regional Office. The decision of the BLR in such cases is final and executory, and any appeal on the same must be filed with the BLR as a motion for reconsideration.


ISSUE: Does the Secretary of Labor have jurisdiction to review the decision of the Bureau of Labor Relations in such a case?


HELD: No. The appellate jurisdiction of the Secretary of labor is limited to a review of cancellation proceedings decided by the BLR in the exercise of its (BLR) exclusive and original jurisdiction. In this case, the BLR exercised its appellate power to review the decision of the Regional Director in a petition to cancel a union’s certificate of registration. The Secretary of Labor has no jurisdiction over such a case since the BLR’s decision in the same is final and not appealable.

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