25 Colegio De San Juan De Letran v Association of AUTHOR: Magsino, Patricia Marie C.

Employees and Faculty of Letran Doctrine: The requirement on both parties of the
[G.R. No.141471, Sept. 18, 2000] performance of the mutual obligation to meet and convene
TOPIC: Duty to bargain collectively promptly and expeditiously in good faith for the purpose of
PONENTE: Kapunan, J. negotiating an agreement was not met by petitioner. They
showed complete lack of interest to bargain
FACTS:
Then president of respondent union Association of Employees and Faculty of Letran, Salvador Abtria initiated th
renegotiation of the last 2 years of the 5 year CBA with petitioner Letran
The union elected a new set of officers that year where private respondent Eleanor Ambas emerged as the newl
elected president, she then proceeded to initiate the renegotiation of the CBA but Letran claimed that the CBA wa
already prepapred for signing
The parties submitted the disputed CBA to a referendum where it was rejected
Petitioner accused the union officers of bargaining in bad faith before the NLRC, the Labor Arbiter ruled for th
petitioner but on appeal this decision was reversed
The parties then agreed to disregard the unsigned CBA and start negotiation on a new 5 year CBA, they submitte
their proposals which was received by the Board of Trustees of the petitioner
Ambas was then informed of a change in her work schedule to which she protested and requested for the issue t
be brought to a grievance machinery under the old CBA
Due to petitioners inaction, the union filed a notice to strike, the parties then met to discuss the ground rules o
the negotiation but the petitioner stopped negotiations upon learning that a new group of employees filed for
petition for certification election because of this, the union finally struck
Secretary of Labor assumed jurisdiction and ordered all the striking employees to return to work and for th
petitioner to accept them back petitioner accepted everyone EXCEPT Ambas prompting them to file pleadings
Labor Secretary declared the petitioner guilty of unfair labor practices and ordered the reinstatement of Ambas an
back wages, the petitioner filed an MR which was denied, and then sought for a petition for review before the C
which dismissed the petition and affirmed the Labor Sec. decision
Hence petition
ISSUE(S):
Is petitioner guilty of unfair labor practices when it suspended negotiations
HELD:
Yes. Petition is denied for lack of merit.
RATIO:
Petitioner failed to show any justification for the Court to depart from the ruling of the appellate court.
Petitioner is guilty of violating Art. 250, and 252 of the Labor Code
Art. 250. Procedure in collective bargaining.The following procedures shall be observed in collective
bargaining: (a) When a party desires to negotiate an agreement, it shall serve a written notice upon the other
party with a statement of its proposals. The other party shall make a reply thereto not later than ten (10)
calendar days from receipt of such notice.
Art. 252. Meaning of duty to bargain collectively.The duty to bargain collectively means the performance o
a mutual obligation to meet and convene promptly and expeditiously in good faith for the purpose of
negotiating an agreement
Petitioner violated Art. 250 by not filing any reply or counter proposal when union submitted their proposals
Petitioner likewise violated Art 252 when it delayed the negotiations numerous times, and showed complete lac
of interest to negotiate the CBA