REPUBLIC OF THE PHILIPPINES DEPARTMENT OF LABOR AND EMPLOYMENT

OFFICE OF THE SECRETARY

MANILA

In re: Labor Dispute at ______________Corporation OS.AJ Case No. _____________ x---------------------x

EX PARTE PETITION FOR ASSUMPTION OF JURISDICTION

_________ Corporation, through the undersigned counsel and unto this Honorable Office, most respectfully files this Petition for the Honorable Secretary of Labor to exercise its power pursuant to Article 263 (g) of the Labor Code of the Philippines and assume jurisdiction over the labor dispute within the petitioner company brought about by the filing of a Notice of Strike by the respondent union and avers: 1. That the _________ Corporation and the _________ Employees Union are presently in the process of renewing their Collective Bargaining Agreement (CBA) FOR 2007-2009; That in the process, the parties declared a deadlock in negotiation that caused the union to file a Notice of Strike which was premised not only on the CBA deadlock; That such notice of strike was filed on May 8, 2007, and in order to actualize the same, the union already conducted its strike vote last ___________________________, where an overwhelming majority of the workers voted for a strike based on the submitted Bargaining Deadlock; That pursuant to Article 263 , of the Labor Code, the union can validly declared an actual strike based on bargaining deadlock on June 7, 2007 or thirty days from the filing of the Notice of Strike last May 8, 2007. That our country cannot afford a strike on vital industries as represented by companies like that of the petitioner in this case, which company is engaged in the production of semiconductors used in electronic devises of almost every industry not only in the Philippines but also in the whole world where such products are exported and used. Such disruption of the companys operations should not happen most especially at this time of world crisis. The indispensability of the petitioner company to the national interest has already been declared by this Honorable Office when it assumed the CBA deadlock involving the same parties last April 22, 2003 under OS-AJ-0013-20-03. (Copy of the Assumption Order attached as Annex C); In view of the foregoing premises and considering that any labor strike conducted in the said industry would not only be a loss to the workers and their families who would be directly affected by it but likewise detrimental to our country and the world as well due to the consequent stoppage of semiconductors production, it is respectfully prayed that this Honorable Office assumes jurisdiction over the instant labor dispute, or at least certify the same to the National Labor Relations Commission for Compulsory Arbitration;

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Other relief and remedies just and equitable are also prayed for.

Greenhills, San Juan, Metropolitan Manila for the City of Manila Philippines. _______________.

LAW & ASSOCIATES Counsel for Petitioner