Case Digest: San Miguel Corp. Employees Union v. Bersamira, G.R. No. 87700 June 13, 1990

  • San Miguel Corporation (SanMig) entered into contracts for merchandising services with independent contractors Lipercon and D'Rite. These contracts specified that the workers employed by the contractors were not SanMig's employees and no employer-employee relationship existed between them.
  • San Miguel Corporation Employees Union-PTWGO (Union) alleged a "labor-only" contracting situation regarding some Lipercon and D'Rite workers who had been continuously working for SanMig for extended periods. The Union demanded regularization of these workers' employment statuses, leading to a notice of strike for unfair labor practices, CBA violations, and union busting.
  • SanMig filed a Complaint for Injunction and Damages, seeking to prevent the Union from representing Lipercon and D'Rite workers, holding a strike vote, and staging strikes or demonstrations.
  • RTC: Issued a Temporary Restraining Order and Writ of Preliminary Injunction stating that the absence of an employer-employee relationship negated the existence of a labor dispute.
WoN the respondent Court correctly assumed jurisdiction over the present controversy and properly issued the Writ of Preliminary Injunction.  NO.

We recognize the proprietary right of SanMig to exercise an inherent management prerogative and its best business judgment to determine whether it should contract out the performance of some of its work to independent contractors. However, the rights of all workers to self-organization, collective bargaining and negotiations, and peaceful concerted activities, including the right to strike in accordance with law (Section 3, Article XIII, 1987 Constitution) equally call for recognition and protection. Those contending interests must be placed in proper perspective and equilibrium.

The Court ruled in favor of the petitioners, stating that the controversy constituted a labor dispute since it involved terms and conditions of employment, regularization of employees, and issues which requires application of existing labor laws. The Court emphasized that labor disputes are not limited to employer-employee relationships and that issues regarding employment terms and representation fall within the scope of labor disputes.


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