Fil. Oil Refinery Vs Fil Oil Supervisory
Fil. Oil Refinery Vs Fil Oil Supervisory
Fil. Oil Refinery Vs Fil Oil Supervisory
Fil Oil Supervisory & Confidential Employees Association And Court of Industrial Relations
Facts: Respondent association is a labor organization duly registered with the Department of Labor. It is composed exclusively
of the supervisory and confidential employees of petitioner corporation. There exists another entirely distinct labor association
composed of the corporation’s rank-and-file employees, the Filoil Employees & Workers Association (FEWA) with which
petitioner executed a collective bargaining agreement. This collective bargaining agreement expressly excluded from its
coverage petitioner’s supervisory and confidential employees, who in turn organized their own labor association, respondent
herein.
Respondent association filed on February 18, 1965 with the industrial court its petition for certification as the sole and
exclusive collective bargaining agent of all of petitioner’s supervisory and confidential employees working at its refinery in
Rosario, Cavite.
Petitioner corporation filed a motion to dismiss the petition claiming that supervisors are not employees within the meaning of
Republic Act 875, the Industrial Peace Act, and that since they are part of management, they do not have the right to bargain
collectively although they may organize an organization of their own and that supervisors form part of management and are
not considered as employees entitled to bargain collectively, arguing that “as supervisors form part and parcel of
management, it is absurd for management to bargain collectively with itself.”
Respondent court denied the dismissal motion. It ruled that under the express provisions of section 3 of the Industrial Peace
Act, “(I)ndividuals employed as supervisors shall not be eligible for membership in a labor organization of employees under
their supervision but may form separate organizations their own.”
Issue: Whether the respondent Supervisors (and confidential employees) may form a labor organization and enjoy right to
collective bargaining?
Held: Yes. Supervisors (and confidential employees), even though they may exercise the prerogatives of management as
regards the rank and file employees are indeed employees in relation to their employer, the company which is owned by the
stockholders and bondholders (capital) and should therefore be entitled under the law to bargain collectively with the top
management with respect to their terms and conditions of employment.
As stated for the SC in AG & P Co. of Manila, Inc. vs. C.I.R., section 3 of the Industrial Peace Act “explicitly provides that
“employees” — and this term includes supervisors — “shall have the right to self-organization, and to form, join or assist labor
organizations of their own choosing for the purpose of collective bargaining through representations of their own choosing
and to engage in concerted activities for the purpose of collective bargaining and other mutual aid or protection” and that
“individuals employed as supervisors … may form separate organizations of their own”. For this reason, supervisors are
entitled to engage in union activities and any discrimination against them by reason thereof constitutes an unfair labor
practice.