Facts:

The case involves the Confederation of Citizens Labor Unions (CCLU), Continental Employees and Laborers Association (CELA), and Redson Employees and Laborers Association (RELA) as petitioners against the National Labor Relations Commission (NLRC), the Secretary of Labor, Federation of Free Workers (FFW), Continental Manufacturing Corporation (CMC), and Redson Textile Manufacturing Corporation as respondents. The events leading to this case began on February 15, 1974, when CMC renewed its collective bargaining agreement with CELA for another three years. This agreement was acknowledged on February 21, 1974. However, on February 12, 1974, FFW filed a petition for a certification election at CMC, which was docketed as NLRC Case No. LR-2751. CMC received a copy of this petition on February 22, 1974. Subsequently, on February 25, 1974, CMC filed the collective bargaining agreement with the Bureau of Labor Relations, which was certified on March 4, 1974.

In a parallel case, on M...

Facts:

1. Collective Bargaining Agreements (CBAs):

   • On February 15, 1974, Continental Manufacturing Corporation (CMC) renewed its collective bargaining agreement (CBA) with the Continental Employees and Laborers Association (CELA), an affiliate of the Confederation of Citizens Labor Unions (CCLU). The CBA was acknowledged on February 21, 1974.
   • On March 4, 1974, Redson Textile Manufacturing Corporation (REDSON) signed a three-year CBA with the Redson Employees and Laborers Association (RELA), effective February 16, 1974. This CBA was filed with the National Labor Relations Commission (NLRC) on March 7, 1974, and certified on March 14, 1974.

2. Petitions for Certification Election:

   • On February 12, 1974, the Federation of Free Workers (FFW) filed a petition for a certification election at CMC, docketed as NLRC Case No. LR-2751. CMC received a copy of this petition on February 22, 1974.
   • On February 25, 1974, FFW filed a similar petition for a certification election at REDSON, docketed as NLRC Case No. LR-2883. REDSON received a copy on March 7, 1974.

3. Responses to Petitions:

   • CMC and REDSON filed answers to the petitions, arguing that the CBAs should bar the certification elections under the "contract-bar rule."
   • CELA-CCLU and RELA-CCLU filed motions to dismiss the petitions on April 23, 1974, and a supplemental motion on May 8, 1974.

4. NLRC Decision:

   • On April 26, 1974, the NLRC consolidated the two cases and granted the petitions for certification elections, directing the Bureau of Labor Relations to conduct the elections within ten days.
   • Petitioners filed a motion for reconsideration and an appeal to the Secretary of Labor, but the NLRC scheduled the elections for July 23, 1974.

5. Court Proceedings:

   • Petitioners filed a petition for certiorari and prohibition with the Supreme Court, seeking to enjoin the NLRC from proceeding with the certification elections.
   • The Supreme Court issued a temporary restraining order on July 22, 1974, preventing the NLRC from opening the ballot boxes or announcing the results.

Issue:

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Ruling:

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Ratio:

1. NLRC's Rule-Making Authority:

   • The NLRC has the authority to issue rules and regulations governing collective bargaining, including the requirement that CBAs be certified to bar certification elections. This authority is derived from Presidential Decree No. 21.

2. Contract-Bar Rule:

   • A CBA must be certified before it can serve as a bar to a certification election. If a petition for certification is filed before the CBA is certified, the CBA cannot bar the election.

3. No Grave Abuse of Discretion:

   • The NLRC did not act with grave abuse of discretion in granting the petitions for certification elections. The NLRC's actions were in accordance with its rules and the law.

4. Presumption of Regularity:

   • Administrative agencies, such as the NLRC, are presumed to have regularly performed their duties. Petitioners failed to provide evidence to rebut this presumption.

5. Exhaustion of Administrative Remedies:

   • Petitioners failed to exhaust administrative remedies by not raising certain issues, such as FFW's membership claims, during the NLRC proceedings. These issues could not be raised for the first time on appeal.

6. Stability of Labor Relations:

   • The certification election process is designed to ensure the free and fair choice of bargaining representatives by employees. The NLRC's decision to hold certification elections was consistent with this principle.