Title
Dong Seung Inc. vs. Bureau of Labor Relations
Case
G.R. No. 162356
Decision Date
Apr 14, 2008
The Supreme Court denies the petitioner's request to cancel the union's registration due to lack of evidence and a reasonable interpretation of the labor code.
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Case Digest (G.R. No. 162356)

Facts:

  • Petition for cancellation of registration of NAMAWU Local 188-Dong Seung Workers Union filed by Dong Seung Incorporated.
  • Grounds for petition: union's application for registration contained a certification that was not under oath and many members denounced the union for employing deceit in obtaining signatures.
  • Department of Labor and Employment (DOLE) granted the petition and cancelled the union's registration.
  • Bureau of Labor Relations (BLR) reversed the decision and allowed the union to remain registered, but required updated documents within 30 days.
  • Petitioner appealed to the Court of Appeals (CA), but CA affirmed the BLR's decision.
  • Petition for Review on Certiorari filed with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • Supreme Court found no reversible error in the CA's decision.
  • Timeliness of the union's appeal is a factual issue and cannot be entertained in a proceeding under Rule 45.
  • Petitioner's evidence, a certification by the Acting Postmaster, was of dubious authenticity and lacking in material details.
  • No reason to impugn the BLR's proceedings as it observed due process and allowed the petitioner to be heard.
  • BLR's interpretation of the requirement for the union secretary's certification to be under oath was upheld.
  • BLR's int...(Unlock)

Ratio:

  • Timeliness of the union's appeal is a factual issue and cannot be entertained in a proceeding under Rule 45.
  • Petitioner's evidence lacked authenticity and material details, undermining its credibility.
  • BLR's proceedings observed due process and allowed the petitioner to be heard, indicating no bias.
  • BLR's i...continue reading

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