Title
Adamson and Adamson, Inc. vs. Court of Industrial Relations
Case
G.R. No. L-35120
Decision Date
Jan 31, 1984
Supervisory and rank-and-file unions affiliated with the same national federation; SC upheld their independence, ruling no violation of labor laws or merger of bargaining units.
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Case Digest (G.R. No. L-35120)

Facts:

  1. Formation of Unions:

    • Adamson & Adamson, Inc. Supervisory Union (FFW) informed the petitioner, Adamson & Adamson, Inc., about its formation on the same day that the Adamson & Adamson, Inc. Salesmen Association (FFW) notified the company of the rank-and-file salesmen's union formation.
    • During the pendency of the case, the rank-and-file employees formed their own union, Adamson & Adamson Independent Workers (FFW).
  2. CIR Proceedings:

    • The Court of Industrial Relations (CIR) dismissed the petition in CIR Case No. 3267-MC, which sought to determine the representation of supervisory employees.
    • The petitioner filed a petition for review on certiorari, challenging the CIR's decision.
  3. Petitioner's Argument:

    • The petitioner argued that the affiliation of the supervisory union, salesmen's association, and rank-and-file union with the same national federation (FFW) violated Section 3 of the Industrial Peace Act.
    • The petitioner contended that this affiliation:
      • Resulted in the indirect affiliation of supervisors and rank-and-file employees with one labor organization.
      • Merged the bargaining units of supervisors and rank-and-file employees.
      • Made the supervisory union lose its independence, becoming an alter ego of the federation.
  4. Respondents' Argument:

    • The respondents argued that supervisory employees could join a rank-and-file union if the rank-and-file employees were not under their supervision.
    • They emphasized that the supervisory union and rank-and-file unions had separate constitutions, by-laws, and certificates of registration.
    • They also noted that the unions submitted separate proposals for collective bargaining agreements.

Issue:

  1. Whether the supervisory union's affiliation with the same national federation (FFW) as the rank-and-file unions violated Section 3 of the Industrial Peace Act.
  2. Whether such affiliation would result in the indirect affiliation of supervisors and rank-and-file employees, merging their bargaining units, and undermining the independence of the supervisory union.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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