Facts:

The case involves two actions filed by the Angat River Irrigation System and its Supervising Project Engineer, Vicente R. Cruz, against the Angat River Workers' Union (PLUM) and the Court of Industrial Relations. These cases are docketed as G.R. Nos. L-10943 and L-10944, and the decision was rendered on December 28, 1957. The Angat River Irrigation System is a section of the Bureau of Public Works responsible for maintaining and operating irrigation systems in Bulacan and neighboring provinces, with its appropriations governed by yearly appropriations acts passed by Congress.

On January 5, 1956, a complaint was lodged by the Acting Prosecutor of the Court of Industrial Relations on behalf of the Angat River Workers' Union, alleging that the Angat River Irrigation System and its supervising engineer committed unfair labor practices. The complaint specified instances of interference, coercion, and discrimination against employees involved in union activities, including dis

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Facts:

Background and Party Involvement

• The Angat River Irrigation System is a division or section of the Bureau of Public Works, maintained and operated as part of the National Government’s irrigation efforts in Bulacan and neighboring provinces.
• The appropriation for the project is included in the General Appropriations Act, affirming its governmental funding and function.
• Petitioners in these cases are the Angat River Irrigation System and its Supervising Project Engineer, Vicente R. Cruz.

Alleged Unfair Labor Practices

• On August 3, 1955, the Angat River Workers’ Union (PLUM) presented a statement of proposals with 15 demands to the employer.
• After the employer failed to act on the union’s proposals:
• The union president personally and in writing inquired about the demands.
• The supervising engineer intimated that continued union activities would result in the dismissal of employees.
• Specific personnel actions included:
• Demotion of Feliciano Clemente from water master to collector.
• Dismissals on September 20, 1955, of officers and active union members Ceferino Roque, Tomas Palileo, and Abelardo Crisostomo.

Certification Proceedings

• On January 9, 1956, PLUM filed a petition for certification as the majority union (Case No. 313-MC).
• The petition asserted that the union was legally permitted by the Department of Labor (under Permit No. 1424-IP) and represented at least 95% of the employees.
• The union sought immediate certification as the sole and exclusive collective bargaining representative, alleging that the employer had refused to negotiate and instead engaged in unfair labor practices.

Jurisdictional and Procedural Issues in the Lower Court

• In the complaint (filing of Case No. 814-ULP on January 5, 1956), respondents (including the Court of Industrial Relations) moved to dismiss the action on the ground that the Angat River Irrigation System is an entity under the Bureau of Public Works and that the Government is immune from suit without its consent.
• The Court of Industrial Relations, by its order dated June 29, 1956, deferred the resolution of the motion to dismiss pending the presentation of evidence and directed a timely filing of an answer by the respondents.
• After a motion to reconsider that order was denied, the petitioners sought relief by instituting special civil actions for prohibition—including the issuance of a writ of preliminary injunction—arguing that the lower court lacked jurisdiction over an agency of the Government.

Status and Nature of the Angat River Irrigation System

• The System is recognized as falling under the direct supervision of the President through the Department of Public Works and Communications, as created by Act No. 2152 (Irrigation Act of 1912).
• Its funding comes directly from appropriations made by Congress, similar to the salaries and wages appropriated for officials of the Bureau of Public Works.
• This fact raised the question of whether the System’s employees, being government employees, are subject to the protections and limitations (e.g., prohibitions against strikes) of the Industrial Peace Act.

Issue:

Unionization and Collective Bargaining Rights

• Whether government employees at the Angat River Irrigation System, engaged in the performance of governmental or proprietary functions, may validly organize into a labor union.
• If unionization is permissible, whether the union may compel the Government to engage in collective bargaining with respect to wages, hours, and other conditions of employment.

Jurisdiction of the Court of Industrial Relations

• Whether the Court of Industrial Relations acquired jurisdiction over the petitioners, considering that the Angat River Irrigation System is an instrumentality of the Government.
• Whether petitioners, by virtue of their status as a government agency without independent legal personality, can be sued without the Government’s express consent.

Determination of Real Party in Interest

• Whether the Angat River Irrigation System, as a government instrumentality, should be considered the proper party to face action for alleged unfair labor practices, or whether the action should have been directed against the Government itself.
• The implications for cases where an entity’s status (as part of or separate from the Government) affects its susceptibility to suit under labor laws.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)