G.R. No. L-29881 - Palomar vs. Court of 1st Instance of Manila, Branch XIV

Plaintiffs Sabina Basa, Bonifacio Basa, Bonifacio Cabalhin, and Primitivo Gallardo were long-time employees of La Dicha La Paz y Buen Viaje Cigar and Cigarette Factory, having joined the company in 1949, 1952, 1960, and 1957 respectively.
On April 21, 1961, the collective bargaining agreement between the Company and the defendant union (Federacion Obrera de la Industria Tabaquera y Otros Trabajadores de Filipinas – FOITAF) was executed, which contained a union shop or closed shop clause mandating that employees who were already union members or newly hired must maintain or join union membership as a condition of continued employment.

The plaintiffs, who are members of Iglesia ni Cristo—a religious sect whose beliefs prohibit joining labor unions—formally resigned from their union membership on August 28, 1964, invoking their constitutional right to freedom of religion.
Their resignation was grounded on Republic Act No. 3350, enacted on June 18, 1961, which provides that closed shop agreements shall not cover members of religious sects that prohibit union affiliation.

In response to the resignation, the Union (through its president, Severino Tabalno) sent a letter on August 31, 1964, giving the plaintiffs fifteen days to reconsider their resignation, failing which the Company would be requested to enforce the union shop clause.
Subsequently, on October 14, 1964, the Company, represented by its president Bienvenido A. Tan, Jr., formally notified the plaintiffs, giving them until October 23, 1964, to reaffiliate with the union on pain of dismissal.

Instead of rejoining the union, the plaintiffs filed the instant action on October 20, 1964, seeking an immediate injunction to prevent dismissal and to stop payroll deductions for union dues and assessments, as well as reimbursement for amounts already collected.
The lower court (Court of First Instance, Branch IV, Quezon City) issued an order on March 31, 1966, enjoining the Company from dismissing the plaintiffs and ordering both the Company and the defendant union to reimburse the deducted union dues and assessments, along with attorney’s fees and costs.
The defendant union subsequently appealed, arguing that the lower court erred in not declaring Republic Act No. 3350 unconstitutional and that the law improperly impaired the contractual union security clause.

Whether the plaintiffs’ resignation from the union, based on their religious convictions, constitutes a legitimate exercise of their constitutional right to freedom of religion.

Whether Republic Act No. 3350, which exempts members of religious sects that proscribe union membership from closed shop agreements, is constitutionally valid.
Whether the enforcement of the closed shop clause, despite the plaintiffs’ religious objections, would contravene their rights under the Constitution.

Whether the statutory amendment through Republic Act No. 3350 unduly impairs the existing contractual obligations (specifically, the union shop clause) between the Company and the labor union.

Whether such impairment is justified by the state’s exercise of its police power for the general welfare and security of employment.
Whether the right to freedom of association permits the individual employee both to join and to refrain from joining a labor union.

Whether the exemption offered by Republic Act No. 3350 discriminates in favor of certain religious groups and violates the constitutional guarantee of equal protection under the law.