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1
ISSUE with HOLDING ii. Having no personality to appeal the Med-Arbiter’s
1. WoN the Labor Arbiter is bound by the ruling of the med-arbiter decision, the employees were then left with no option
finding no employer-employee relationship constitutes res but to pursue their illegal dismissal case before the
judicata. NO. LA.
a. The Court held that the Med-Arbiter has the authority to iii. If the illegal dismissal case were to be dismissed on
determine the existence of an ER-EE relationship between the basis of the Med-Arbiter’s decision finding no ER-
the parties in a petition for certification election. EE relationship, which the Union could not appeal
i. Under Art. 226 (now Art. 232), the BLR has the because of their member-employees’ dismissal, this
original and exclusive jurisdiction to decide all would be tantamount to denying due process to
disputes, grievances or problems arising from or the complainants in the illegal dismissal case.
affecting labor-management relations in all
workplaces, whether agricultural or non-agricultural. DISPOSITIVE PORTION
ii. Necessarily, in the exercise of this jurisdiction over WHEREFORE, we DENY the petition. We AFFIRM the decision of the
labor-management relations, the med-arbiter (under CA.
the BLR) has the authority, original and exclusive, to
determine the existence of an ER-EE relationship SO ORDERED.
between the parties.
iii. The med-arbiter’s decision is only appealable to the OTHER NOTES
Secretary of Labor. Art 226 (now 232) was superseded by EO 251 which created the
b. However, as held in the cases of Manila Golf & Country NCMB and absorbed the conciliation and mediation functions of the
Club vs IAC and Sandoval Shipyards vs Pepito, the BLR (as per maam’s syllabus).
decision of the Med-Arbiter in a certification election case,
by the nature of such proceedings, does not foreclose
further dispute between the parties as to the existence or DIGESTER: Xave
non-existence of employer-employee relationship between
them.
c. Also, the Med-Arbiter’s order in this case dismissing the
petition for certification election on the basis of non-
existence of ER-EE relationship was issued after the
employees were dismissed from employment.
i. Because of this, the union, without its member-
employees, was stripped of its personality to
challenge the Med-Arbiter’s decision in the
certification election case (there were would be no
one to represent).