Case Facts
Respondents filed a petition for
certification of pre-election with
the DOLE. The Med-Arbiter
approved the pre-election.
Petitioner filed for cancellation of
the certification due to the failure
of respondent to submit its
financial statements to the
Bureau of Labor Relations. The
Med-Arbiter still ruled in favor of
respondents. Petitioner appealed
The Heritage Hotel Manila vs. the decision to the regional
NUWHRAIN director of the DOLE. The
GR 178296 Regional director still rendered a
decision in favor of respondents,
which prompted petitioners to
appeal the decision to the
director of the Bureau of Labor
Relations. The director of the BLR
inhibited from the issue, as he
was previously the counsel of
respondents. The Secretary of
Labor resolved the issue in the
stead of the BLR director. She
ruled in favor of respondents.
Petitioner then filed for certiorari,
challenging the jurisdiction of the
DOLE Secretary. An appeal from
the decision of the Regional
Director is supposed to be under
the jurisdiction of the BLR.
Issue/s Ruling Jurisprudence
Araneta, et al. v. Hon. M.
Yes. It is without question that
the appeal from the decision of
the regional office is within the
jurisdiction of the BLR. Given the
Does DOLE have Jurisdiction circumstances, the BLR director
over the appeal? inhibited himself. Petitioner
insists that the case should have
gone to the subordinates of the
BLR director. However, this
happens in cases where the
director is incapacitated. This
does not obtain as the director
merely inhibited himself. On the
other hand, the Secretary of
DOLE has powers of supervision
and control over the BLR. As
such, it may validly step into the
shoes of the BLR director and
resolve the issue.
Gatmaitan, et al.,27
pronounced that, if a certain
power or authority is vested by
law upon the Department
Secretary, then such power or
authority may be exercised
directly by the President, who
exercises supervision and control
over the departments. This
principle was incorporated in the
Administrative Code of 1987,
which defines "supervision and
control" as including the
authority to act directly whenever
a specific function is entrusted by
law or regulation to a
subordinate.28 Applying the
foregoing to the present case, it
is clear that the DOLE Secretary,
as the person exercising the
power of supervision and control
over the BLR, has the authority
to directly exercise the quasi-
judicial function entrusted by law
to the BLR Director.