Facts:

The case involves the Chrysler Philippines Labor Union (CPLU) as the petitioner and Hon. Francisco Estrella, Acting Director of the Bureau of Labor Relations, the Associated Labor Union (ALU), and Chrysler Philippines Corporation (CPC) as respondents. The petition for certiorari was filed on July 30, 1977, to contest the resolution of Acting Director Estrella, which upheld the dismissal of CPLU's petition for a certification election by Med-Arbiter Conrado G. Sagun. The dismissal was based on the assertion that CPLU lacked independent legal personality from its mother union, ALU.

CPLU was registered with the Bureau of Labor Relations under Registration Certificate No. 4664-IP, dated August 20, 1965, and affiliated with ALU in March 1974, resulting in a new registration certificate that included the suffix "ALU." During this affiliation, CPLU-ALU entered into a Collective Bargaining Agreement (CBA) with CPC on March 26, 1974, which was effective until November...

Facts:

Background of the Parties

1. Petitioner: Chrysler Philippines Labor Union (CPLU) is a labor organization registered with the Bureau of Labor Relations (BLR) under Registration Certificate No. 4664-IP, dated August 20, 1965.
2. Respondents:
   • Associated Labor Union (ALU): A national union or federation with its own registration certificate.
   • Chrysler Philippines Corporation (CPC): The employer of the hourly-paid rank-and-file employees represented by CPLU-ALU.
   • Hon. Francisco Estrella: Acting Director of the Bureau of Labor Relations.

Affiliation and Collective Bargaining Agreement (CBA)

3. In March 1974, CPLU affiliated with ALU, resulting in the issuance of a new registration certificate under the name "Chrysler Philippines Labor Union-ALU" (CPLU-ALU).
4. On March 26, 1974, CPLU-ALU entered into a CBA with CPC, effective from November 30, 1973, to November 30, 1976.

Petition for Certification Election

5. On June 21, 1976, an "Urgent Petition for Certification Election" was filed by Rogelio Enriquez and 300 other employees, seeking to replace CPLU-ALU as the bargaining agent. This petition was dismissed by Med-Arbiter Roman A. Tabaquin on September 28, 1976, on the grounds that:

   • It was barred by the existing CBA.
   • It was filed four months before the CBA's expiration.
   • It was filed in the name of individual petitioners, not their union.

6. The dismissal was affirmed by Acting Director Francisco Estrella, citing Article 256 of the Labor Code, which prohibits certification elections during the existence of a CBA, except within 60 days prior to its expiration.

Disaffiliation and Legal Personality of CPLU

7. On January 17, 1977, CPLU filed a "Petition for Direct Certification with Preliminary Injunction," alleging that ALU represented a minority of employees and that CPLU had disaffiliated from ALU. The petition was supported by a resolution signed by 350 out of approximately 550 employees, disaffiliating from ALU and maintaining CPLU as an independent union.
8. CPLU-ALU filed a motion to dismiss, arguing that CPLU no longer existed as an independent union and that the petition was filed after the 60-day freedom period.
9. Med-Arbiter Conrado G. Sagun dismissed CPLU's petition on March 10, 1977, citing the unresolved issue of CPLU's legal personality. This dismissal was affirmed by Acting Director Estrella, who ruled that CPLU had no legal personality independent of CPLU-ALU.

Supreme Court Proceedings

10. CPLU filed a special civil action for certiorari with the Supreme Court, alleging grave abuse of discretion by Acting Director Estrella.
11. The Supreme Court issued a temporary restraining order on August 8, 1977, preventing the certification of any new CBA between CPLU-ALU and CPC.
12. During the pendency of the case, CPLU-ALU and CPC entered into a new CBA, ratified by 80% of the hourly-paid employees. CPLU-ALU argued that this ratification rendered the petition moot and academic.

Issue:

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Ruling:

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Ratio:

1. Legal Personality of Disaffiliated Unions: A duly registered local union does not lose its legal personality upon disaffiliation from a national union. Disaffiliation merely restores the local union's independence, and re-registration is not required.
2. Certification Election and CBA Ratification: The ratification of a CBA does not automatically resolve the issue of representation. A certification election is necessary to determine the true choice of the employees, especially when there are competing claims of majority representation.
3. Judicial Review of BLR Decisions: Decisions of the Bureau of Labor Relations are subject to judicial review, particularly in cases of grave abuse of discretion, lack of jurisdiction, or error of law.

Disposition

The Supreme Court reversed the order of Acting Director Estrella and remanded the case to the Bureau of Labor Relations for the conduct of a certification election. The temporary restraining order was lifted, effective after the certification election.