Case Digest (G.R. No. 79025)
Facts:
The case involves Benguet Electric Cooperative, Inc. (BENECO) as the petitioner and Hon. Pura Ferrer-Calleja, Director of the Bureau of Labor Relations, along with the Beneco Employees Labor Union (BELU) as respondents. The events leading to this case began on June 21, 1985, when the Beneco Workers' Labor Union-Association of Democratic Labor Organizations (BWLU-ADLO) filed a petition for direct certification as the sole and exclusive bargaining representative for all rank-and-file employees of BENECO located in Alapang, La Trinidad, Benguet. BWLU-ADLO claimed that BENECO employed 214 rank-and-file employees, with 198 (92.5%) supporting the petition. They asserted that no certification election had been conducted in the past 12 months and that there was no existing collective bargaining representative for the employees in question.
In opposition, BELU contended that it had been certified as the exclusive bargaining representative of the workers since an order from a med...
Case Digest (G.R. No. 79025)
Facts:
- Petition for Certification Election: On June 21, 1985, the Beneco Worker's Labor Union-Association of Democratic Labor Organizations (BWLU-ADLO) filed a petition for direct certification as the sole and exclusive bargaining representative of all rank-and-file employees of Benguet Electric Cooperative, Inc. (BENECO). The petition claimed that 198 out of 214 employees supported the petition, no certification election had been conducted in the last 12 months, and no collective bargaining agreement existed.
- Opposition by BELU: The Beneco Employees Labor Union (BELU) opposed the petition, asserting that it had been certified as the sole bargaining representative since 1980 and that pending cases involving bargaining deadlock and unfair labor practice barred the representation question.
- BENECO's Motion to Dismiss: BENECO argued that it was a non-profit cooperative and that its employees, being members and joint owners, were ineligible to form or join labor unions.
- Med-Arbiter's Order: On September 2, 1985, the med-arbiter ordered a certification election but limited it to rank-and-file employees who were non-members and not involved in the cooperative's ownership. Only 37 employees met this criterion.
- Certification Election: On October 1, 1986, a certification election was held. BENECO protested, claiming that only 4 employees were non-members and eligible to vote. However, 83 employees voted, with BELU receiving 49 votes.
- Protest and BLR Decision: BENECO's protest was dismissed by the med-arbiter and affirmed by the Bureau of Labor Relations (BLR) director, who certified BELU as the exclusive bargaining agent.
Issue:
- Whether the BLR director committed grave abuse of discretion in certifying BELU as the sole and exclusive bargaining representative of BENECO's rank-and-file employees.
- Whether employees who are members and co-owners of a cooperative are eligible to form, assist, or join labor unions for collective bargaining purposes.
Ruling:
The Supreme Court granted BENECO's petition, annulled the BLR director's resolution, and set aside the certification election. The Court ruled that:
- Employees who are members and co-owners of a cooperative cannot form or join labor unions for collective bargaining purposes, as they cannot bargain with themselves or their co-owners.
- Only non-member employees are eligible to form or join labor unions.
- The certification election was invalid because ineligible employees (members of the cooperative) were allowed to vote, making it impossible to determine if BELU was duly elected by eligible voters.
- A new certification election was ordered, limited to non-member employees.
Ratio:
- (Unlock)