Facts:

The cases of The Agricultural Credit and Cooperative Financing Administration (ACCFA) vs. Confederation of Unions in Government Corporations and Offices (CUGCO) and others, and The Agricultural Credit Administration (ACA) vs. ACCFA Supervisors' Association, ACCFA Workers' Association were resolved by the Supreme Court of the Philippines in a decision dated November 29, 1969. The ACCFA was a government agency created by Republic Act No. 821, later reorganized and renamed ACA under the Land Reform Code (Republic Act No. 3844). The ACCFA Supervisors' Association (ASA) and the ACCFA Workers' Association (AWA) are labor unions representing supervisors and rank-and-file employees, respectively.

In G.R. No. L-21484, on September 4, 1961, a collective bargaining agreement was established between the unions and the ACCFA, valid for one year starting July 1, 1961. However, shortly thereafter, the unions expressed discontent regarding alleged violations of the agreement, le

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Facts:

Background of the Cases

• Two separate appeals by certiorari (G.R. No. L-21484 and G.R. No. L-23605) were consolidated into one decision because the parties (except CUGCO) and the principal issues were almost identical.
• The Agricultural Credit and Cooperative Financing Administration (ACCFA) was a government agency created under Republic Act No. 821. Later, under the Land Reform Code (Republic Act No. 3844), its administrative machinery was reorganized and its name changed to the Agricultural Credit Administration (ACA).
• The respondents include labor organizations—the ACCFA Supervisors’ Association (ASA) and the ACCFA Workers’ Association (AWA)—representing supervisors and rank-and-file employees of the ACCFA/ACA, as well as proceedings before the Court of Industrial Relations (CIR).

Collective Bargaining Agreement and Labor Dispute

• On September 4, 1961, a collective bargaining agreement was entered into by the ACCFA and the Unions, effective for one year from July 1, 1961.
• Soon after its execution, the Unions protested alleged violations and non-implementation of the agreement, culminating in a strike declared on October 25, 1962 and ended a month later when the workers voluntarily returned on November 26, 1962.
• On October 30, 1962 the Unions, along with its mother union (CUGCO), filed a complaint before the CIR (Case No. 3450-ULP) claiming unfair labor practices, including:
• Violation of the collective bargaining agreement intended to discourage self-organization;
• Discriminatory practices in promotions;
• Refusal to bargain in good faith.

Proceedings in the CIR

• The ACCFA denied the allegations, raising defenses such as lack of jurisdiction, expiration of the contract, and non-compliance with conditions (e.g., lack of Presidential approval for fringe benefits).
• The CIR, however, ordered the ACCFA to cease acts that discouraged union self-organization, to implement the provisions of the bargaining agreement (including payment of a monthly living allowance), and to bargain expeditiously with the unions.
• The ACCFA’s motion for reconsideration was denied by the CIR en banc in a resolution dated April 25, 1963.

Certification Election Petition and Reorganization

• During the pendency of the unfair labor practice case, the ACA’s supervisory and workers’ unions filed a petition for a certification election with the CIR (Case No. 1327-MC) seeking recognition as the exclusive bargaining agents for employees.
• The trial court directed notification and posting of its order and eventually certified the unions as the sole and exclusive bargaining representatives, a decision affirmed by the CIR en banc on August 24, 1964.
• Subsequently, the ACA challenged the certification by petitioning for certiorari with an urgent motion to stay the CIR order—raising the issue of whether the agency’s functions were governmental or proprietary.

Governmental Nature of the ACA

• The reorganization under the Agricultural Land Reform Code, along with Executive Order No. 75, placed the ACA under the Land Reform Project Administration, indicating an integration of personnel and policies across agencies.
• Detailed provisions of the Land Reform Code (Sections 110–118) and related legislative and executive actions clarified that the ACA’s functions were aimed at the implementation of the land reform program—a purely governmental function.
• Statements from Senate debates and administrative endorsements further highlighted that the ACA was designed as a public service institution, not a profit-making or proprietary entity, with appointments made by the President and personnel governed by Civil Service laws.

Fringe Benefits Controversy

• A portion of the dispute centered on the enforcement of fringe benefits stipulated in the 1961 collective bargaining agreement.
• The ACCFA argued that such benefits were not enforceable because of a condition that required prior approval by the Office of the President.
• Evidence showed that the condition was satisfied when the Office of the President approved the agreement (albeit with a proviso) and subsequent arrangements were made on July 1, 1963, ensuring that benefits already accrued were paid.
• Despite payment of accrued fringe benefits, the court had to address whether further benefits could be claimed if the collective bargaining unit certification was invalidated due to the governmental nature of the ACA.

Issue:

Jurisdiction and Nature of Functions

• Whether the Court of Industrial Relations had jurisdiction over the case, which hinged on whether the ACCFA (later ACA) was engaged in governmental functions or proprietary activities.
• Whether the reorganization under the Land Reform Code altered the essential character of the agency, thereby affecting its eligibility to be subject to collective bargaining arrangements.

Validity and Enforcement of the Collective Bargaining Agreement

• Whether the 1961 collective bargaining agreement was valid and, if so, whether it had lapsed.
• Whether the condition requiring Presidential approval for fringe benefits was a valid term incorporated by reference in the agreement, and if its fulfillment rendered the benefits enforceable.

Allegations of Unfair Labor Practice

• Whether the ACCFA/ACA committed acts of unfair labor practice in violation of the collective bargaining agreement.
• Whether such actions amounted to a refusal to bargain in good faith in contravention of the terms agreed upon.

Certification Election and Collective Bargaining Rights

• Whether the Unions were entitled to a certification election to serve as the exclusive bargaining representatives given that the agency performed functions of a governmental nature.
• The broader issue concerning whether employees in agencies discharging governmental functions could validly demand collective bargaining and engage in strike actions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)