Title
Arguelles vs. Young
Case
G.R. No. L-59880
Decision Date
Sep 11, 1987
A labor union sought a certification election for workers in one hacienda; employer argued 30% support requirement across four haciendas. BLR ordered election, upheld by Supreme Court, emphasizing discretion in resolving representation issues.
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Case Digest (G.R. No. L-59880)

Facts:

Petition for Certification Election:
On April 7, 1980, the Federation of Unions of Rizal (FUR), a legitimate labor organization, filed a petition for certification election supported by 32 workers of Hacienda Emma, one of four sugarcane plantations owned by petitioner George Arguelles. FUR claimed it had 32 of the 35 workers in Hacienda Emma as members, no other union existed, and no certification election had been held in the past 12 months.

Motion to Dismiss:
On May 1, 1980, Arguelles filed a motion to dismiss the petition, arguing that the 30% requirement under the Labor Code was not met. He contended that since the management consisted of four haciendas with 131 workers sharing the same working conditions and community of interest, the petition needed support from 39 workers (30% of 131) to be valid.

Motion to Intervene:
On May 11, 1981, the Workers Amalgamated Union of the Philippines (WAUP), another legitimate labor organization, filed a motion to intervene, claiming majority support among the workers and stating that no certification election had been held in the past 12 months.

Regional Office Decision:
On June 2, 1980, the Regional Office of the Ministry of Labor and Employment (MOLE) in Bacolod City denied the motion to dismiss and ordered the holding of a certification election in Hacienda Emma, allowing participation from FUR and WAUP. Arguelles filed a motion for reconsideration, which was denied. The case was elevated to the Bureau of Labor Relations (BLR).

BLR Resolution:
On December 15, 1981, the BLR issued a resolution affirming the Regional Office’s decision but modified it to include all four haciendas. The BLR ruled that while 36 workers were needed to meet the 30% requirement, the presence of WAUP created a genuine representation issue that could be resolved through a certification election.

Motion for Reconsideration and Petition:
Arguelles filed a motion for reconsideration, which was denied on January 28, 1982. He then filed the present petition for certiorari, challenging the BLR’s jurisdiction and asserting that the certification election violated the one-unit employer concept.

Issue:

  1. Whether the Bureau of Labor Relations (BLR) had jurisdiction to order a certification election based on a petition supported by 30% of workers in one hacienda, despite the existence of four haciendas with a shared community of interest.
  2. Whether strict compliance with the 30% requirement under the Labor Code is mandatory for ordering a certification election.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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