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FACTS: ISSUE: Whether the employees from the Cabuyao, San Fernando and Otis
1. In SMCSEU v. Laguesma, SC held that even if the supervisory Plants should only be in one bargaining Unit.
employees 3 and 4 and the exempt employees of SMFI handle
confidential data regarding internal business operations, they are not to RULING AND RATIO: YES
be considered confidential employees because the same do not pertain to 1. The Court explained that the employees of San Miguel Corporation
LabRel (negotiation and settlement of grievances) Magnolia Poultry Products Plants of Cabuyao, San Fernando, and Otis
a. They were allowed to form an appropriate bargaining unit for constitute a single bargaining unit, which is not contrary to the one-
CB. company, one-union policy.
b. Employees belonging the 3 plants (Cabuyao, San Fernando, 2. An appropriate bargaining unit is defined as a group of employees
Ortis) of SMC-Magnolia constitute a single bargaining unit. of a given employer, comprised of all or less than all of the entire
2. Pursuant to this decision, DOLE conducted pre-election conferences. body of employees, which the collective interest of all the employees,
a. However, there was a discrepancy in the list of eligible voters. consistent with equity to the employer, indicate to be best suited to
3. SMFI questioned the eligibility of some of its employees to vote because serve the reciprocal rights and duties of the parties under the
some do not belong to the bargaining unit which the Union seeks to collective bargaining provisions of the law.
represent or no employment relationship exists. 3. While the existence of a bargaining history is a factor that may be
a. Some of the employees should not be allowed to vote because reckoned with in determining the appropriate bargaining unit, the same
they are confidential employees; not covered by the bargaining is not decisive or conclusive. Other factors must be considered. The test
unit; job grade level 4 but performing managerial work; belong of grouping is community or mutuality of interest. This is so because the
to Ugong plant; non-SMFI employees; members of other basic test of an asserted bargaining unit’s acceptability is whether or not
unions. it is fundamentally the combination which will best assure to all
4. Union: employees the exercise of their collective bargaining rights.
Certain factors, such as specific line of work, working conditions, location of
work, mode of compensation, and other relevant conditions do not affect or
impede their commonality of interest. Although they seem separate and
distinct from each other, the specific tasks of each division are actually
interrelated and there exists mutuality of interests which warrants the
formation of a single bargaining unit.