G.R. No. 118562 - Alliance of Nationalist and Genuine Labor Organizations vs. Samahan ng mga Manggagawang Nagkakaisa sa Manila Bay Spinning Mills at J.P. Coats

Petitioner: Alliance of Nationalist and Genuine Labor Organization (ANGLO-KMU), a duly registered labor organization.
Respondent: Samahan ng Mga Mangagawang Nagkakaisa sa Manila Bay Spinning Mills and J.P. Coats (SAMANA BAY), an affiliate of ANGLO-KMU.
Relationship: SAMANA BAY, while initially represented by ANGLO in negotiations, later sought to disaffiliate due to issues involving alleged neglect of its welfare and corruption within ANGLO’s leadership.

ANGLO, on behalf of SAMANA BAY, entered into a Collective Bargaining Agreement (CBA) with Manila Bay Spinning Mills and J.P. Coats Manila Bay, Inc. on November 1, 1991.
On December 4, 1993, the Executive Committee of SAMANA BAY resolved to disaffiliate from ANGLO, based on accusations of neglect of duty and corruption.
The resolution was unanimously ratified by the members of SAMANA BAY, reflecting a shift in allegiance and a desire for autonomous representation.

On April 4, 1994, SAMANA BAY filed a petition with the Bureau of Labor Relations to stop remittance of federation dues to ANGLO, alleging that the corporations refused to honor the union’s disaffiliation resolution.
In response, ANGLO counteracted by removing the existing officers and board members of SAMANA BAY and appointing a new set of officers who were recognized by the corporations.
ANGLO contended that the disaffiliation was void because (a) the procedural requirements had not been complied with, and (b) it was effected outside the 60-day freedom period as mandated by P.D. 1391.

The Med-Arbiter initially ruled that the disaffiliation was void yet upheld the illegality of the ouster of SAMANA BAY’s officers.
On September 23, 1994, a resolution by the Department of Labor and Employment modified the Med-Arbiter’s order:

Declaring SAMANA BAY’s disaffiliation from ANGLO as valid.
Instructing the corporations to stop remitting federation dues to ANGLO and instead remit them to SAMANA BAY’s treasurer.
Enjoining ANGLO-KMU from interfering in the internal affairs of SAMANA BAY.

ANGLO’s motion for reconsideration of this order was denied, prompting the filing of the present petition for certiorari under Rule 65.
The petition specifically raised two major issues:

The validity of the disaffiliation.
The validity of the ouster of individual private respondents from their positions.

Sub-issue: Did ANGLO fail in observing the procedural requirements for a valid disaffiliation?
Sub-issue: Was the act of disaffiliation precluded by the requirement of the 60-day freedom period under P.D. 1391?

Whether the ousting of the individual private respondents (the officers of SAMANA BAY) by ANGLO-KMU was valid.

Sub-issue: Can ANGLO, following disaffiliation, validly remove or replace SAMANA BAY’s officers?
Sub-issue: Does the severance of the agency relationship upon valid disaffiliation affect the legitimacy of such actions?