Case Digest (G.R. No. L-38955-56)
Facts:
Confederation of Citizens Labor Unions (CCLU), Continental Employees and Laborers Association (CELA), and Redson Employees and Laborers Association (RELA) sought certiorari and prohibition to annul NLRC actions in NLRC Cases Nos. LR-2751 and LR-2883 and to enjoin the scheduled certification election on July 23, 1974. Federation of Free Workers (FFW) had filed the petitions for certification elections on February 12, 1974 for Continental Manufacturing Corporation (CMC) and on February 25, 1974 for Redson Textile Manufacturing Corporation (REDSON); both petitions were granted by the NLRC in a decision dated April 26, 1974, ordering elections within ten days. Petitioners received the NLRC decision on May 11, 1974 and sought reconsideration and appeal, but the NLRC set the elections for July 23, 1974, prompting the instant petition, while this Court initially issued a temporary restraining order.
The collective bargaining agreements involved were renewed or signed around mid-February to early March 1974, and petitioners invoked the contract-bar rule, arguing that NLRC lacked authority to require certification before a bargaining agreement could bar an election and that NLRC allegedly committed various procedural irregularities. The temporary restraining order was later addressed, and the case reached final resolution on the merits.
Issues:
- Whether the NLRC lacked authority to modify the contract-bar rule by requiring a collective bargaining agreement to be certified before it could bar a petition for certification election.
- Whether the certification elections could not be ordered on the ground that the collective bargaining agreements were of reasonable duration and already provided substantial benefits.
- Whether the NLRC erred in granting FFW’s petitions on the premise that FFW was “raiding” CCLU locals and that this caused damage without legal injury.
- Whether NLRC committed a jurisdictional irregularity by taking cognizance of the certification petitions despite the parties’ grievance procedure in the collective bargaining agreements.
- Whether the NLRC decision was void for allegedly not being personally prepared by the Commissioners and Chairman.
- Whether petitioners were denied their day in court because the petitions allegedly did not require proof of the claimed union membership percentage.
- Whether NLRC attempted to implement its decision even before petitioners received the Secretary of Labor’s action on the appeal.
Ruling:
The Court dismissed the petition and lifted the temporary restraining order, holding that NLRC had jurisdiction and did not commit actionable grave abuse of discretion. It sustained NLRC’s approach to certification elections and rejected the contract-bar challenge, emphasizing NLRC’s authority to promulgate rules for certification elections and the governing statutory scheme under Republic Act No. 875.
It further held that alleged errors were, at most, errors of judgment; that petitioners could not raise issues not raised before NLRC; that the alleged implementation irregularity was effectively corrected by the cancellation of the scheduled election and pre-election conference; and that petitioners failed to show grave abuse of discretion amounting to lack or excess of jurisdiction.
Ratio:
On the contract-bar issue, the Court held that the NLRC could require filing and certification of collective bargaining agreements as a condition for them to operate as bars, because the NLRC was created by Presidential Decree No. 21 and was expressly empowered to promulgate rules on collective bargaining and related matters. Even assuming petitioners’ view of the prior rule, the Court found that the bargaining agreements relied upon by petitioners were not yet certified, or not yet even signed as of the relevant filing dates, so petitioners’ factual basis for a bar failed.
The Court also relied on Section 12 of Republic Act No. 875, which, based on the uncontroverted allegations that no certification election had been held in the previous twelve months and that FFW claimed the requisite representation percentages, required ordering an election upon a proper petition. It rejected petitioners’ grievance-procedure and “void decision” theories, holding that any NLRC misstep on those points did not constitute jurisdictional error, and it invoked the presumption that official duty was regularly performed by quasi-judicial administrative agencies. Finally, it refused to consider membership-percentage and other arguments not raised before the NLRC, and it treated the alleged premature implementation as cured by the subsequent cancellation of the election schedule.
Doctrine:
- The NLRC has authority under Presidential Decree No. 21 to promulgate rules governing collective bargaining and certification elections, including requirements on filing and certification of collective bargaining agreements.
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