The Supreme Court has affirmed that before a union member can bring a case to the Department of Labor and Employment (DOLE) regarding internal union matters, they must first exhaust all remedies available within the union’s constitution and by-laws. This means the member must try to resolve the issue through the union’s internal processes before seeking intervention from external government bodies. This requirement ensures that unions have the first opportunity to address and resolve disputes internally, promoting self-governance and preventing premature legal intervention.

Diamonon’s Dissent: When Internal Union Processes Must Precede External Legal Battles

The case of Jesus B. Diamonon v. Department of Labor and Employment revolves around a dispute within the National Congress of Unions in the Sugar Industry of the Philippines (NACUSIP) and the Philippine Agricultural, Commercial and Industrial Workers Union (PACIWU). Diamonon, a high-ranking officer in both unions, was removed from his positions and subsequently filed a complaint with the DOLE, alleging unauthorized disbursement of union funds by other officers. The central legal question is whether Diamonon prematurely sought DOLE intervention without first exhausting the remedies provided within the unions’ own constitutions and by-laws.

Diamonon’s complaint was initially dismissed by the Med-Arbiter for lack of personality, given his removal from the union positions. While this dismissal was appealed, the Undersecretary of DOLE later affirmed the dismissal, but on a different ground: Diamonon’s failure to exhaust administrative remedies within the unions. Diamonon argued that the DOLE Undersecretary committed grave abuse of discretion by changing the grounds for dismissal on appeal. However, the Supreme Court disagreed, emphasizing that appellate courts, including administrative bodies, have broad discretionary power to consider errors not originally assigned, especially when those errors are crucial for a just resolution.

The court highlighted that Diamonon failed to comply with Section 2, Rule VIII, Book V of the Implementing Rules and Regulations of the Labor Code, which requires a complainant to demonstrate that internal remedies have been exhausted or are unavailable. The Implementing Rules and Regulations of the Labor Code explicitly states that:

“Sec. 2. Who may file. If the issue involves the entire membership of the union, the complaint shall be signed by at least 30% of the membership of the union.

In addition to the above requirement, the petition on its face must show that the administrative remedies provided for in the constitution and by-laws have been exhausted or such remedies are not readily available to the complaining members through no fault of their own. x x x”

Moreover, the unions’ constitutions and by-laws stipulated specific procedures for addressing internal disputes. For example, the NACUSIP constitution stated that the actions of the National Executive Board are subject to review by the National Convention or the General Council. Similarly, the PACIWU constitution outlined a detailed procedure for settling internal disputes, including investigation by a committee and review by the Executive Board. Diamonon did not seek recourse before the National Convention regarding his complaint, rendering his action premature.

The principle of **exhaustion of administrative remedies** is a cornerstone of administrative law. This doctrine requires parties to pursue all available administrative channels before seeking judicial intervention. The rationale is that administrative bodies, equipped with specialized knowledge and expertise, should be given the first opportunity to resolve disputes within their purview. This approach prevents overburdening the courts with cases that could potentially be resolved internally. This principle is not merely a procedural technicality; it is rooted in the idea that administrative agencies are best positioned to address issues within their regulatory domain.

The Supreme Court has consistently upheld the importance of exhausting administrative remedies. In Carale v. Abarintos, the Court emphasized that when internal grievance mechanisms exist, they should be utilized before resorting to external bodies. This promotes a hierarchical system where disputes are resolved at the lowest possible level, fostering efficiency and reducing the strain on the judicial system. The exhaustion requirement ensures that administrative agencies have the opportunity to correct their own errors, clarify ambiguities, and provide a complete record for potential judicial review.

Applying this principle to Diamonon’s case, the Court found that his failure to seek recourse within the unions’ internal mechanisms was a fatal flaw. By bypassing these established procedures, Diamonon prematurely sought the intervention of the DOLE, thereby undermining the unions’ ability to self-regulate and resolve internal conflicts. This premature action was deemed a significant procedural lapse, justifying the dismissal of his complaint.

Furthermore, the Court addressed the argument that the DOLE Undersecretary committed grave abuse of discretion by changing the ground for dismissal on appeal. The Court clarified that appellate bodies have the authority to consider issues not explicitly raised by the parties, especially when such issues are essential for a just and complete resolution. This broad discretionary power allows appellate bodies to correct errors and ensure that justice is served, even if it means addressing issues beyond the initial scope of the appeal. The Court, in fact, has broad discretionary power to waive the lack of assignment of errors and consider errors not assigned:

(a)	Grounds not assigned as errors but affecting the jurisdiction of the court over the subject matter;
(b)	Matters not assigned as errors on appeal but are evidently plain or clerical errors within contemplation of law;
(c)	Matters not assigned as errors on appeal but consideration of which is necessary in arriving at a just decision and complete resolution of the case or to serve the interests of a justice or to avoid dispensing piecemeal justice;
(d)	Matters not specifically assigned as errors on appeal but raised in the trial court and are matters of record having some bearing on the issue submitted which the parties failed to raise or which the lower court ignored; Supreme
(e)	Matters not assigned as errors on appeal but closely related to an error assigned;
(f)	Matters not assigned as errors on appeal but upon which the determination of a question properly assigned, is dependent.

In this instance, the failure to exhaust administrative remedies was a critical issue that warranted consideration, even if it was not the original basis for the Med-Arbiter’s dismissal. The Court’s decision underscores the importance of adhering to established procedural rules and respecting the authority of administrative bodies to resolve disputes within their respective domains. The ruling serves as a reminder that premature resort to external bodies can undermine the effectiveness of internal grievance mechanisms and disrupt the orderly administration of justice.

FAQs

What was the key issue in this case?	The central issue was whether Jesus Diamonon prematurely filed a complaint with the DOLE without first exhausting the remedies available within his union’s constitution and by-laws. The Supreme Court addressed the principle of exhaustion of administrative remedies.
What is the doctrine of exhaustion of administrative remedies?	This doctrine requires parties to pursue all available administrative channels for resolving a dispute before seeking judicial intervention. The rationale is to give administrative bodies the first opportunity to address issues within their expertise.
Why is the exhaustion of administrative remedies important?	It promotes a hierarchical system where disputes are resolved at the lowest possible level, fostering efficiency and reducing the strain on the judicial system. It also ensures that administrative agencies have the opportunity to correct their own errors.
What did the DOLE Undersecretary decide in this case?	The DOLE Undersecretary affirmed the dismissal of Diamonon’s complaint, citing his failure to exhaust administrative remedies within the unions. This decision was upheld by the Supreme Court.
Did the Supreme Court find any abuse of discretion by the DOLE Undersecretary?	No, the Supreme Court found no grave abuse of discretion. It clarified that appellate bodies have the authority to consider issues not explicitly raised by the parties, especially when such issues are essential for a just resolution.
What specific provisions of the unions’ constitutions were relevant?	The NACUSIP constitution stated that the actions of the National Executive Board are subject to review by the National Convention or the General Council. The PACIWU constitution outlined a detailed procedure for settling internal disputes.
What was Diamonon’s main argument in the Supreme Court?	Diamonon argued that the DOLE Undersecretary committed grave abuse of discretion by changing the grounds for dismissal on appeal. He claimed that the Undersecretary should not have considered the issue of exhaustion of administrative remedies.
What is the practical implication of this ruling for union members?	Union members must first attempt to resolve disputes internally, following the procedures outlined in their union’s constitution and by-laws, before seeking intervention from the DOLE or other external bodies. Failure to do so may result in the dismissal of their complaints.
What happens if a union member bypasses internal procedures and goes straight to the DOLE?	Their case is likely to be dismissed for failure to exhaust administrative remedies. The administrative bodies will expect union members to first seek resolution within their union before elevating the issue externally.

In conclusion, the Supreme Court’s decision in Diamonon v. Department of Labor and Employment reaffirms the critical importance of exhausting administrative remedies before seeking external legal intervention in internal union disputes. This ruling underscores the need for union members to adhere to established procedural rules and respect the authority of administrative bodies to resolve disputes within their respective domains, promoting self-governance and preventing premature legal actions.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Jesus B. Diamonon, G.R. No. 108951, March 07, 2000