Case Digest (G.R. No. L-21484)
Facts:
In G.R. No. L-21484, the Agricultural Credit and Cooperative Financing Administration (ACCFA), created under Republic Act No. 821 and later renamed Agricultural Credit Administration (ACA) under the Land Reform Code (Republic Act No. 3844), faced an unfair labor practice complaint filed on October 30, 1962 by the ACCFA Supervisors’ Association (ASA), the ACCFA Workers’ Association (AWA), and the Confederation of Unions in Government Corporations and Offices (CUGCO). These unions challenged alleged violations of the one-year collective bargaining agreement of September 4, 1961, which took effect July 1, 1961, and protested the ACCFA’s refusal to implement fringe benefits, discriminatory promotions, and failure to bargain in good faith. The Court of Industrial Relations (CIR), in its March 25, 1963 decision, ordered ACCFA to cease discouraging union activities, to implement the contract (including a ₱30 living allowance), and to bargain expeditiously. A motion for reconsiderationCase Digest (G.R. No. L-21484)
Facts:
- Case G.R. No. L-21484
- On September 4, 1961, the ACCFA Supervisors’ Association (ASA) and the ACCFA Workers’ Association (AWA) entered into a collective bargaining agreement (CBA) with the Agricultural Credit and Cooperative Financing Administration (ACCFA), effective July 1, 1961 to June 30, 1962.
- The Unions later protested alleged violations of the CBA and, on October 25, 1962, declared a strike which ended when they returned to work on November 26, 1962.
- On October 30, 1962, the Unions and CUGCO filed an unfair labor practice (ULP) complaint with the Court of Industrial Relations (CIR) (Case No. 3450-ULP) alleging:
- Violation of the CBA to discourage union self-organization;
- Discrimination in promotions; and
- Refusal to bargain in good faith.
- The ACCFA denied jurisdiction, challenged the legality and expiration of the CBA, and moved for reconsideration.
- On March 25, 1963, the CIR ordered the ACCFA:
- To cease and desist ULPs;
- To implement the CBA, including payment of a ₱30 monthly living allowance; and
- To bargain in good faith.
- The ACCFA’s motion for reconsideration was denied on April 25, 1963, prompting this certiorari appeal.
- Case G.R. No. L-23605
- Republic Act No. 3844 (Land Reform Code), signed August 8, 1963, reorganized ACCFA into the Agricultural Credit Administration (ACA).
- On March 17, 1964, ASA and AWA filed a petition for certification election with the CIR (Case No. 1327-MC) to be exclusive bargaining agents for ACA supervisors and rank-and-file employees.
- The ACA challenged jurisdiction, the Unions’ majority status, and the right of government employees to belong to such unions.
- By joint manifestation (May 7, 1964), the ACA and the Unions agreed the Unions represented the majority; only legal issues were to be resolved.
- On May 21, 1964, the CIR certified ASA and AWA as exclusive bargaining representatives; this order was affirmed en banc on August 24, 1964.
- On October 2, 1964, the ACA filed for certiorari with an urgent motion to stay; on October 6, 1964, the Court granted a stay and required adequate allegations. ACA complied and this appeal ensued.
Issues:
- Does the CIR have jurisdiction over ACCFA/ACA when it performs governmental rather than proprietary functions?
- Is the September 4, 1961 CBA valid, unexpired, and enforceable, particularly as to its fringe-benefit provisions?
- Was there a sufficient basis—legal or factual—for the CIR’s finding of unfair labor practice by the ACCFA?
- Can the CIR enforce a CBA that has already expired?
- May a labor organization composed of government employees petition for a certification election and compel collective bargaining?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)