Facts:

The case involves George Arguelles, the petitioner, against Romeo A. Young, Officer-in-Charge of the Bureau of Labor Relations, Ministry of Labor and Employment, and two labor organizations: the Federation of Unions of Rizal (FUR) and the Workers Amalgamated Union of the Philippines (WAUP). The events leading to this case began on April 7, 1980, when FUR filed a petition for certification election with the Regional Office of the Ministry of Labor and Employment (MOLE) in Bacolod City. The petition was supported by the signatures of 32 workers from Hacienda Emma, one of four haciendas owned by Arguelles, claiming that it represented a majority of the workers there. Arguelles contested the petition on May 1, 1980, arguing that the 30% requirement under the Labor Code was not met, as the haciendas collectively employed 131 workers, necessitating 39 signatures for compliance.

Subsequently, WAUP filed a motion to intervene, asserting it had majority support among the workers an...

Facts:

Procedural Background

• On April 7, 1980, the private respondent, Federation of Unions of Rizal (FUR), a legitimate labor organization, filed a petition for certification election with the Regional Office of the Ministry of Labor and Employment (MOLE).
• The petition, supported by the written signatures of 32 workers from Hacienda Emma, alleged that the union commanded the majority of workers in that hacienda (32 out of 35) and asserted that no other union represented the workforce.
• It also emphasized that no certification election had been held in the plantation for the past 12 months.

Objections and Motions

• On May 1, 1980, petitioner George Arguelles filed a motion to dismiss the petition for certification election.
• Arguelles contended that the Labor Code’s 30% support requirement had not been met because the petition was based solely on signatures from Hacienda Emma.
• Given that the petitioner's management included four haciendas with a total of 131 workers, he argued that a minimum of 39 supporting signatures was necessary.
• On May 11, 1981, Workers Amalgamated Union of the Philippines (WAUP) filed a motion to intervene.
• WAUP claimed that it enjoyed majority support of the rank and file workers across the management.
• It further alleged that no certification election had been held within the preceding 12 months and that there was no recognized bargaining agent.
• On June 2, 1980, respondent filed its opposition to the motion to dismiss.
• It argued that Hacienda Emma was distinct from other haciendas.
• The respondent maintained that there was no community interest uniting the other haciendas, while also suggesting that the “one employer unit” principle should allow exceptions when grouping workers was impractical.

MOLE Intervention and Subsequent Orders

• On June 2, 1981, the MOLE’s Regional Office in Bacolod City issued an order directing the holding of certification elections within the premises of Hacienda Emma.
• This order allowed the participation of both FUR and WAUP.
• It also mandated the construction of polling booths for the orderly conduct of the election.
• On June 9, 1981, petitioner filed a motion for reconsideration.
• Arguelles argued that the MOLE’s order did not address his earlier motion to dismiss.
• He contended that the med-arbiter lacked the authority to order the election.
• On June 17, 1981, med-arbiter Correa issued an order elevating the entire records of the case to the Bureau of Labor Relations (BLR).

BLR Resolution and Petition for Certiorari

• On December 15, 1981, the BLR, with public respondent Romeo A. Young acting as arbiter, issued a resolution.
• The resolution modified the requirement by stating that only 36 supporting workers were necessary to satisfy the 30% requirement.
• It noted a shortfall of 4 signatures but considered this immaterial in light of WAUP’s intervention, which raised representation issues best settled by a certification election.
• On January 11, 1982, petitioner filed another motion for reconsideration on two grounds:
• The resolution was contrary to law.
• It was issued without or in excess of jurisdiction.
• In its Resolution of January 28, 1982, the public respondent denied the renewed motion for reconsideration.
• A temporary restraining order (TRO) was issued on March 22, 1982, enjoining further proceedings until the petitioners and respondents filed their comments.
• Subsequent submissions by the respondents were consolidated as their memorandum in the Resolution of March 7, 1983, after which the case was deemed submitted for decision.

Issue:

Jurisdictional Authority

• Whether the Bureau of Labor Relations acquired jurisdiction to order the holding of a certification election among all the rank and file workers of petitioner’s sugar cane plantation (comprising four different haciendas) based solely on petition signatures from one hacienda.

Compliance with the 30% Requirement

• Whether the petition, supported by 32 signatures from Hacienda Emma, satisfies the Labor Code’s requirement given that the management has four haciendas with a total of 131 workers.
• Whether the lack of 39 signatures (as argued by petitioner) precludes the ordering of a certification election.

Exercise of Discretion

• Whether the BLR, in modifying the numerical requirement and proceeding with the certification election despite the alleged deficiency, acted with grave abuse of discretion or within its permissible range of discretion.
• Whether the presence of an intervenor (WAUP) that raised a genuine representation issue justified proceeding with the certification election.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)