Case Digest (G.R. No. L-35120)
Facts:
The case involves Adamson & Adamson, Inc. as the petitioner and the Court of Industrial Relations (CIR) along with the Adamson & Adamson Supervisory Union (FFW) as respondents. The events leading to this case began when the Adamson & Adamson Supervisory Union informed the petitioner about its formation on the same date that the Adamson & Adamson Salesmen Association (FFW) notified the company of the establishment of a union for rank-and-file salesmen. The CIR dismissed the petition filed by Adamson & Adamson, Inc. in CIR Case No. 3267-MC, which sought to challenge the union's representation of supervisory employees. This dismissal prompted the petitioner to file a petition for review on certiorari. During the pendency of this petition, the rank-and-file employees formed their own union, named Adamson & Adamson, Independent Workers (FFW). The petitioner raised a single assignment of error, arguing that the CIR erred in allowing the supervisory union...
Case Digest (G.R. No. L-35120)
Facts:
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).
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.
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.
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:
- 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.
- 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)