Case Digest (G.R. No. L-11273)
Facts:
The case involves Acoje Mines Employees and Acoje United Workers Union as petitioners and appellants against Acoje Labor Union (Pelta) and Acoje Mining Company as respondents and appellees. The events leading to this case began in August 1955 when 334 employees of Acoje Mines Inc. filed a petition for a certification election with the Court of Industrial Relations. They claimed that there were two legitimate labor organizations within the company: the Acoje United Workers Union (Workers Union) and the Acoje Labor Union (Pelta). The employees sought an election to determine which union would represent them for collective bargaining purposes. The Workers Union expressed its willingness to participate in the election, while Pelta opposed it, citing two main defenses: the existence of a collective bargaining contract with the Mining Company that was valid for four years (1954-1958) and an ongoing investigation into an unfair labor practice complaint (Case No. 255-ULP) against the...
Case Digest (G.R. No. L-11273)
Facts:
Background of the Case:
- The case involves a petition for review regarding the suspension of proceedings for a certification election filed by 334 employees of Acoje Mines Inc. in August 1955.
- The employees sought to determine the true representative for collective bargaining between two labor organizations: the Acoje United Workers Union (Workers Union) and the Acoje Labor Union (Pelta).
Existing Collective Bargaining Agreement:
- Pelta objected to the certification election, citing an existing four-year collective bargaining agreement (1954-1958) between Pelta and Acoje Mining Company.
- Pelta also raised a pending unfair labor practice complaint (Case No. 255-ULP) alleging that the Mining Company had assisted in organizing and controlling the Workers Union.
Industrial Court’s Decision:
- The Court of Industrial Relations suspended the certification election pending the resolution of the unfair labor practice case, following its established practice.
- The Workers Union opposed the suspension, but the court maintained its decision, emphasizing the need to ensure that the election reflects the true sentiment of the workers without employer interference.
Petitioners’ Argument:
- The petitioners argued that under Section 12(c) of Republic Act 875, it is mandatory for the court to order a certification election if at least 10% of the employees in the bargaining unit request it.
- They contended that the suspension of the election curtailed the rights of the majority.
Issue:
- Whether the Court of Industrial Relations acted legally in suspending the certification election pending the resolution of the unfair labor practice case.
- Whether the existence of a collective bargaining agreement and a pending unfair labor practice complaint are valid exceptions to the mandatory certification election rule under Section 12(c) of Republic Act 875.
Ruling:
The Supreme Court denied the petition for review, upholding the suspension of the certification election. The Court ruled that:
- The suspension was justified due to the pending unfair labor practice complaint alleging company domination of the Workers Union.
- The Industrial Court acted prudently and legally in suspending the election to ensure that the workers’ true sentiments would be reflected without employer interference.
- The Court declined to rule on the issue of the existing collective bargaining agreement, as the suspension was already justified on other grounds.
Ratio:
- (Unlock)