The Supreme Court has affirmed the importance of due process within labor unions, ruling that union officers can be held liable for unfair labor practices if they fail to follow their own constitution and by-laws when suspending or expelling members. This decision underscores the right of union members to self-organization and protection against arbitrary actions by union leadership, ensuring that internal union procedures are fair and transparent.

When Internal Disputes Escalate: Can Union Leaders Abuse Their Power?

Allan M. Mendoza, a member of the Manila Water Employees Union (MWEU), found himself in conflict with the union’s officers over non-payment of increased union dues. This dispute led to his suspension and eventual expulsion from the union, which he claimed was a violation of his rights and an act of unfair labor practice. The central legal question was whether the union officers had followed the proper procedures in disciplining Mendoza, and whether their actions constituted an infringement on his right to self-organization.

The case began when MWEU informed Mendoza that he had not fully paid the increased union dues due to a missing check-off authorization. He was warned of potential sanctions for non-payment. Subsequently, the union’s grievance committee recommended a 30-day suspension, which the MWEU Executive Board approved. Mendoza, however, contested the suspension and sought to appeal to the General Membership Assembly, a right he believed was guaranteed by the union’s Constitution and By-Laws. His appeal was denied, and he was later charged again, leading to a second suspension and ultimately, expulsion from the union. Each time, Mendoza’s attempts to appeal to the General Membership Assembly were ignored.

In response, Mendoza filed a complaint against the union officers for unfair labor practices, damages, and attorney’s fees before the National Labor Relations Commission (NLRC). He argued that his illegal termination from MWEU and the discriminatory provisions in the proposed collective bargaining agreement (CBA) constituted unfair labor practices. The Labor Arbiter initially referred the case back to the union level for the General Assembly to act on Mendoza’s appeal. However, the NLRC reversed this decision, stating it lacked jurisdiction over the case, deeming it an intra-union dispute falling under the purview of the Bureau of Labor Relations (BLR).

The Court of Appeals (CA) upheld the NLRC’s decision, finding that the issues raised by Mendoza were primarily intra-union disputes, with the exception of the alleged threat made by a union officer against members of a rival union. The CA reasoned that even this was not an actionable wrong. The Supreme Court, however, partly reversed the CA’s ruling, holding that while some of Mendoza’s claims involved intra-union matters, his charge of unfair labor practices fell within the original and exclusive jurisdiction of the Labor Arbiters. The Court emphasized that **unfair labor practices violate the constitutional right of workers and employees to self-organization.**

The Supreme Court scrutinized the MWEU’s Constitution and By-Laws, specifically regarding the process for appealing suspensions and expulsions. The Court found that Mendoza had indeed filed timely appeals after both his second suspension and his expulsion. However, the MWEU Executive Board failed to act on these appeals, effectively denying Mendoza his right to due process within the union. **This failure to follow their own internal procedures constituted a violation of Mendoza’s rights as a union member.**

The Court highlighted that the requirement for a petition to convene the general assembly through a certain percentage of union member signatures did not apply in Mendoza’s case. The Executive Board had a primary obligation to act on his appeals before the matter could be escalated to the general membership. By not acting on the appeals, the respondents effectively prevented Mendoza from exercising his rights and caused him to be suspended, disqualified from running for union office, and ultimately expelled from the union. The Court, in citing Article 247 of the Labor Code, underscored the concept of unfair labor practices:

Article 247. Concept of unfair labor practice and procedure for prosecution thereof. — Unfair labor practices violate the constitutional right of workers and employees to self-organization, are inimical to the legitimate interests of both labor and management, including their right to bargain collectively and otherwise deal with each other in an atmosphere of freedom and mutual respect, disrupt industrial peace and hinder the promotion of healthy and stable labor-management relations.

Building on this principle, the Court found the union officers guilty of unfair labor practices under Article 249 (a) and (b) of the Labor Code, specifically violating Mendoza’s right to self-organization, unlawfully discriminating against him, and illegally terminating his union membership. As members of the governing board of MWEU, the respondents were presumed to know, observe, and apply the union’s constitution and by-laws. Their repeated violations and disregard of Mendoza’s rights as a union member connote willfulness and bad faith.

The Court also addressed the issue of damages, stating that the respondents’ actions warranted an award of moral damages. **Moral damages are recoverable when they are the proximate result of the defendant’s wrongful act or omission.** The Court awarded Mendoza P100,000.00 in moral damages, P50,000.00 in exemplary damages, and attorney’s fees equivalent to 10% of the total award.

FAQs

What was the key issue in this case?	The key issue was whether the union officers committed unfair labor practices by failing to follow their own constitution and by-laws when suspending and expelling a union member. The Supreme Court ultimately ruled in favor of the member, affirming his right to due process within the union.
What are unfair labor practices?	Unfair labor practices are actions by employers or labor organizations that violate the constitutional right of workers to self-organization. These practices can include interfering with, restraining, or coercing employees in the exercise of their rights.
What is the role of the Bureau of Labor Relations (BLR)?	The BLR has jurisdiction over inter-union and intra-union conflicts, as well as disputes arising from labor-management relations. However, cases involving unfair labor practices fall under the jurisdiction of the Labor Arbiters.
What is the significance of a union’s constitution and by-laws?	A union’s constitution and by-laws are the governing rules that dictate how the union operates and protects the rights of its members. Union officers must adhere to these rules, and failure to do so can result in legal consequences.
What are moral damages?	Moral damages are compensation for mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injuries. They may be recovered if they are the proximate result of the defendant’s wrongful act or omission.
What are exemplary damages?	Exemplary damages are imposed, by way of example or correction for the public good, in addition to other damages. They are designed to permit the courts to reshape behavior that is socially deleterious in its consequence.
What is the right to self-organization?	The right to self-organization is the right of employees to form, join, or assist labor organizations of their own choosing for purposes of collective bargaining. This right is guaranteed by the Labor Code and the Constitution.
What happens if union officers violate a member’s right to appeal?	If union officers violate a member’s right to appeal a suspension or expulsion, it can be considered an unfair labor practice. This can lead to legal action, including awards of damages and attorney’s fees.

The Supreme Court’s decision serves as a crucial reminder to union leaders of their responsibility to uphold the rights of their members and adhere to the principles of due process. This ruling reinforces the importance of transparency and fairness within labor unions, ensuring that internal disputes are resolved in a just and equitable manner.

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: Allan M. Mendoza vs. Officers of Manila Water Employees Union (MWEU), G.R. No. 201595, January 25, 2016