Case Digest (G.R. No. L-11029)
Facts:
The case involves two petitions: G.R. No. L-11029 filed by Benguet Consolidated, Inc. and Balatoc Mining Company against Bobok Lumber Jack Association, and G.R. No. L-11065 filed by Benguet-Balatoc Workers Union against the same association and other parties. The events leading to the case began in the sub-province of Benguet, Mountain Province, where the petitioners operate in the mining industry, employing approximately 6,000 workers across five camps: Balatoc, Antamok, Acupan, Bobok Timber Project, and Irisan Lime Quarry. On December 9, 1953, the Court of Industrial Relations issued an order declaring these camps as separate bargaining units. Following a certification election, the Benguet-Balatoc Workers Union was certified as the exclusive bargaining agency for four of the camps, while the United Mine Workers Union was certified for the Irisan camp.
Subsequently, on January 24, 1955, the Bobok Lumber Jack Association filed a petition for a certification election in th...
Case Digest (G.R. No. L-11029)
Facts:
Background of the Companies and Operations:
- Petitioners Benguet Consolidated, Inc. and Balatoc Mining Co. are engaged in the mining industry, jointly managing mining claims in Benguet, Mountain Province. They employ approximately 6,000 workers distributed across five camps: Balatoc, Antamok Mining Camp, Acupan Mining Camp, Bobok Timber Project, and Irisan Lime Quarry.
- Balatoc Camp: Houses mills, administration offices, warehouses, and shops. Ore from Antamok and Acupan is milled here.
- Antamok Mining Camp: Conducts underground and surface mining operations.
- Acupan Mining Camp: Also conducts mining operations, with ore sent to Balatoc for milling.
- Bobok Timber Project: Produces timber and lumber exclusively for the companies.
- Irisan Lime Quarry: Produces lime primarily for milling purposes.
Certification of Bargaining Units:
- On December 9, 1953, the Court of Industrial Relations (CIR) declared the five camps as separate bargaining units. Certification elections were held, resulting in:
- Benguet-Balatoc Workers Union winning representation in Balatoc, Antamok, Acupan, and Bobok camps.
- United Mine Workers Union winning representation in the Irisan camp.
Petitions for Certification Elections:
- Bobok Lumber Jack Association: Filed a petition on January 24, 1955, seeking a certification election in the Bobok Timber Project (Case No. 225-MC).
- Benguet Consolidated Mining Company Laborers Union: Filed a petition on February 19, 1955, seeking certification elections in Acupan, Antamok, and Balatoc camps (Case No. 235-MC).
- Benguet-Balatoc Workers Union: Filed a petition on March 14, 1955, requesting the five camps be declared a single employer unit and certifying it as the exclusive representative (Case No. 231-MC).
CIR Decision:
- On May 29, 1956, the CIR ruled that the five camps should remain separate bargaining units. The court cited factors such as:
- The geographical separation of the camps (up to 60 km between Antamok and Acupan).
- The presence of superintendents in each camp.
- Differences in the nature of work in each camp.
- The system had operated satisfactorily since 1953.
Appeals:
- Petitioners and the Benguet-Balatoc Workers Union sought reconsideration, which was denied. They appealed, arguing that maintaining separate units could lead to strikes in one camp paralyzing operations in others.
Issue:
- (Unlock)
Ruling:
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Ratio:
Appropriateness of Separate Bargaining Units:
- The CIR's decision was based on valid factors, including the geographical separation of the camps, differences in the nature of work, and the satisfactory operation of the system since 1953.
- The Court emphasized that the prime consideration in determining a bargaining unit is whether it best serves the employees' interests without inequity to the employer.
No Abuse of Discretion:
- The CIR is a specialized tribunal entrusted with determining proper bargaining units. Its findings were cogent and supported by evidence.
- The possibility of strikes in one camp affecting others existed even before the 1953 decision, and no new factors had arisen to justify changing the system.
Nature of Certification Proceedings:
- Certification proceedings are investigatory, aimed at determining proper bargaining units and ascertaining employees' choice of representatives. The Court found no reason to interfere with the CIR's discretion in this case.
Local Unions and Employee Preferences:
- The existence of local unions like the Bobok Lumber Jack Association highlighted the preference of workers for separate representation, further supporting the CIR's decision.
The Supreme Court concluded that the CIR's decision was well-founded and should not be disturbed.