Facts:

The case revolves around the petition filed by the Associated Trade Unions-ATU (ATU-KILUSAN) against Hon. Carmelo G. Noriel, who served as the Director of the Bureau of Labor Relations, alongside the Federation of Free Workers (Synthetic Marketing and Industrial Corporation Chapter) and the Synthetic Marketing and Industrial Corporation. This certiorari proceeding was initiated on January 16, 1979. The events leading up to the case began when on September 13, 1977, the Federation of Free Workers submitted a petition for a certification election among the regular rank-and-file employees of the Synthetic Marketing and Industrial Corporation. The petition claimed that the Federation represented a majority of the workers and included signatures from more than 30% of the total workforce, acknowledging the existence of another union, the ATU-KILUSAN, along with a Collective Bargaining Agreement (CBA) that was set to expire on October 31, 1977. The ATU-KILUSAN and the Synthetic Marketi

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Facts:

1. Petition for Certification Election: On September 13, 1977, the local chapter of the Federation of Free Workers (FFW) filed a petition for a certification election among the regular rank-and-file employees of Synthetic Marketing and Industrial Corporation. The petition claimed that FFW had the support of more than 30% of the workforce and attached signatures of union members. It acknowledged the existence of another union, the Associated Trade Unions-ATU (ATU-KILUSAN), and a Collective Bargaining Agreement (CBA) set to expire on October 31, 1977.

2. Opposition to the Petition: Both the company and ATU-KILUSAN opposed the petition, arguing that it was contract-barred due to the existence of a duly registered CBA between the company and ATU-KILUSAN, which was entered into on May 10, 1977. FFW, however, challenged the validity of the CBA, claiming it was executed prematurely (5 months and 21 days before the expiration of the old CBA) and was not ratified by the members of the bargaining unit.

3. Med-Arbiter’s Order: On January 9, 1977, the Med-Arbiter ordered a certification election. ATU-KILUSAN appealed this decision to the Bureau of Labor Relations (BLR).

4. BLR Director’s Resolution: On May 29, 1978, BLR Director Carmelo C. Noriel affirmed the Med-Arbiter’s order for a certification election and decertified the new CBA between ATU-KILUSAN and the company, citing its premature execution and lack of ratification.

5. Petition for Review: Dissatisfied with the BLR Director’s resolution, ATU-KILUSAN filed a petition for review with the Supreme Court, seeking to overturn the order for a certification election.

Issue:

1. Procedural Due Process: Whether the Med-Arbiter and BLR Director denied ATU-KILUSAN procedural due process by ordering a certification election without prior inquiry or investigation.

2. Contract-Bar Rule: Whether the renewed CBA between ATU-KILUSAN and the company constitutes a bar to the holding of a certification election.

3. Validity of the CBA: Whether the CBA, executed prematurely and without ratification, is valid and enforceable.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)