Title
Asian Design and Manufacturing Corp. vs. Ferrer-Calleja
Case
G.R. No. 77415
Decision Date
Jun 29, 1989
The Bureau of Labor Relations has jurisdiction to rule on protest against a certification election, affirming the election's validity while placing the employer as a mere bystander.
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Case Digest (G.R. No. 77415)

Facts:

  • The case involves Asian Design and Manufacturing Corporation (ADMACOR) as the petitioner and Hon. Pura Ferrer-Calleja, Director of the Bureau of Labor Relations, along with the Southern Philippines Federation of Labor-Kilusang Mayo Uno (KMU) as respondents.
  • A certification election was ordered on May 21, 1986, by the Labor Relations Division, Regional Office VII in Cebu City, following a petition from the Buklod ng Manggagawang Pilipino (BMP), a labor union at ADMACOR's rattan furniture factory in Mandaue City, Cebu.
  • On May 19, 1986, several factory workers initiated a strike without prior notice to the Bureau of Labor Relations.
  • Despite the strike, the certification election proceeded on May 21, 1986, where 413 out of 423 voting workers selected the Southern Philippines Federation of Labor (SPFL) as their exclusive bargaining agent.
  • ADMACOR filed a complaint for illegal strike and illegal picketing against the workers after the election.
  • On May 23, 1986, ADMACOR sought to annul the certification election, claiming the strike made the election day not a regular business day as per Section 2, Rule VI, Book V of the Omnibus Rules Implementing the Labor Code.
  • The Med-Arbiter dismissed ADMACOR's complaint on August 5, 1986, affirming SPFL's status as the exclusive bargaining agent.
  • ADMACOR's appeal to the Bureau of Labor Relations was dismissed on November 24, 1986, and a motion for reconsideration was denied on January 21, 1987.
  • ADMACOR argued that the Bureau exceeded its jurisdiction by ruling on the legality of the strike in relation to the election protest.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the Bureau of Labor Relations did not exceed its jurisdiction in affirming the validity of the certification election.
  • The Court held that the certification election was condu...(Unlock)

Ratio:

  • The Supreme Court reasoned that the Bureau of Labor Relations acted within its jurisdiction by focusing solely on the validity of the certification election, which is under its purview.
  • The legality of the strike was deemed a separate issue, falling under the jurisdiction ...continue reading

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