SSSEA vs. Bathan-Velasco

The Court held that a party must exhaust administrative remedies before resorting to the courts; failure to appeal the order of the Bureau of Labor Relations Director to the Secretary of Labor pursuant to Article 259 of the Labor Code warrants the dismissal of the petition for prematurity.

Respondent ACCESS filed a petition for certification election with the Bureau of Labor Relations (BLR) to determine the sole and exclusive bargaining representative of the SSS rank-and-file employees. The BLR ordered the election, which was held on October 11, 1991. ACCESS garnered the highest number of votes. Petitioner SSSEA filed an election protest and a motion to nullify the election, which the BLR Director denied. SSSEA filed another protest regarding the regional offices, which the BLR Officer-in-Charge likewise denied, declaring ACCESS the winner and certifying it as the exclusive bargaining representative.

• Certification Election: Respondent ACCESS filed a petition for certification election with the Bureau of Labor Relations (BLR) on September 28, 1989. The BLR ordered the election on August 24, 1990. The election was held on October 11, 1991, with ACCESS obtaining 1,378 votes, SSSEA obtaining 1,116 votes, and "No Union" obtaining 40 votes.
• Election Protests: On October 16, 1991, SSSEA filed an election protest and/or motion to annul the certification election. BLR Director Calleja denied the protest on March 20, 1992. On September 29, 1992, SSSEA filed another protest regarding the regional offices.
• BLR Resolution: On November 18, 1992, respondent Velasco denied the second protest, declared ACCESS the winner, and certified ACCESS as the sole and exclusive bargaining representative. Respondent Velasco denied SSSEA's motion for reconsideration on January 25, 1993.

• Petitioner argued that the certification election should not have proceeded because of the pendency of a formal charge of a company-initiated, dominated, or supported union with the Bureau of Labor Relations.
• Petitioner contended that no certification election was held in the regional offices of respondent SSS on October 11, 1991, resulting in an incomplete certification election that rendered the proclamation of ACCESS as the winner null and void.

• Procedural Issues: Whether petitioner exhausted administrative remedies before resorting to the courts by appealing the BLR Director's order to the Secretary of Labor.
• Substantive Issues: Whether the certification election was invalid due to the pendency of a union domination charge and the failure to hold elections in the regional offices.

• Procedural: The Court ruled that petitioner failed to exhaust administrative remedies. Pursuant to Article 259 of the Labor Code, petitioner should have appealed the BLR Director's order to the Secretary of Labor. Because petitioner failed to take this appeal, the premature resort to the courts warranted dismissal of the petition.
• Substantive: The Court declined to resolve the substantive issues because they were factual in nature. A petition for certiorari under Rule 65 is limited to questions of jurisdiction or grave abuse of discretion; it does not extend to evaluating the sufficiency of evidence or resolving factual issues such as the conduct of elections or the status of a pending charge.

• Exhaustion of Administrative Remedies — A party must exhaust all available administrative remedies before resorting to the courts. This doctrine allows the administrative agency the opportunity to decide the matter correctly and prevents premature judicial intervention. The Court applied this doctrine to dismiss the petition because petitioner failed to appeal the BLR Director's order to the Secretary of Labor as provided under the Labor Code.
• Factual Issues in Certiorari — Factual issues are not a proper subject of an original petition for certiorari before the Supreme Court. The Court's power of review under Rule 65 is limited to questions of jurisdiction or grave abuse of discretion of judicial or quasi-judicial tribunals or officials. The Court applied this principle to decline resolving petitioner's allegations of election irregularities, which required an evaluation of the sufficiency of evidence.

• "The rule is well-entrenched that a party must exhaust all administrative remedies before resorting to the courts. The premature invocation of the intervention of the court is fatal to one's cause of action."
• "Factual issues are not proper subject of an original petition for certiorari before the Supreme Court, as its power to review is limited to questions of jurisdiction or grave abuse of discretion of judicial or quasi-judicial tribunals or officials."

• Lopez vs. City of Manila, G.R. No. 127139, February 19, 1999 — Cited as controlling precedent supporting the doctrine of exhaustion of administrative remedies.
• University of the Philippines vs. Catungal Jr., 272 SCRA 221 (1997) — Cited as controlling precedent supporting the doctrine of exhaustion of administrative remedies.
• Dy vs. Court of Appeals, G.R. No. 121587, March 9, 1999 — Cited as controlling precedent establishing that premature invocation of court intervention is fatal to a cause of action.
• Premiere Development Bank vs. National Labor Relations Commission, 293 SCRA 49 (1998) — Cited as controlling precedent establishing that factual issues are not a proper subject of an original petition for certiorari.
• Toyota Autoparts, Philippines, Inc. vs. Director, Bureau of Labor Relations, G.R. No. 13104, March 2, 1999 — Cited as controlling precedent holding that judicial review does not extend to an evaluation of the sufficiency of evidence upon which the proper labor officer based their determination.

• Article 259, Labor Code — Provides that any party to an election may appeal the order or results of the election as determined by the Med-Arbiter directly to the Secretary of Labor and Employment. The Court held that petitioner's failure to take this appeal meant it failed to exhaust administrative remedies.

Davide, Jr., C.J., Puno, Kapunan, and Ynares-Santiago, JJ.