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Diokno v. Cacdac, July 4, 2007
In the union elections of the First Line Association of Meralco Supervisory Employees (FLAMES), a legitimate labor organization, the Committee on Election (COMELEC) rejected several candidates. Private respondents filed a Petition before the Med-Arbitration Unit of DOLE. Petitioners filed a Petition with the COMELEC seeking to disqualify private respondents. COMELEC declared private respondents disqualified to run and/or participate in the elections. Eventually, COMELEC proclaimed Diokno, et. al., as winners in the elections.
Private respondents filed with DOLE a Petition to nullify the order of their disqualification, nullify the election proceedings and declare holding of a new election. Another group filed a separate petition questioning the elections.
Med-Arbiter decided in favor of private respondents. On appeal, Director of BLR affirmed in toto the decision of the Med-Arbiter. CA found petitioners’ appeal to be bereft of merit.
Whether the Bureau of Labor Relations has jurisdiction over the case despite failure of private respondents to exhaust administrative remedies within the union.
Yes. Art. 226 of the Labor Code is explicit in declaring that the Bureau of Labor Relations (BLR) has the original and exclusive jurisdiction on all inter-union and intra-union conflicts.
The controversy in the case is an intra-union dispute. The dispute is within or inside FLAMES, a labor union. At issue is the propriety of the disqualification of private respondents Data, et. al., by the FLAMES COMELEC in the 7 May 2003 elections. The Petition which was initiated by Daya, et. al., before the BLR was properly within its cognizance, it being an intra-union dispute.