Access to Confidential Matters in the Field of Labor Relations

Confidential employees, by the very nature of their functions, assist and act in a confidential capacity to, or have access to confidential matters of, person who exercise managerial functions in the field of labor relations. Therefore, the rationale behind the ineligibility of managerial employees to form, assist or join a labor union was held equally applicable to them. An important element of the "confidential employee rule" is the employee's need to use labor relations information. Thus, in determining the confidentiality of certain employees, a key question frequently considered is the employees' necessary access to confidential labor relations information. (G.R. No. 110399; August 15, 1997)