G.R. No. 190120 - CAAP-Employees' Union vs. Civil Aviation Authority of the Philippines

Petitioner Eagle Ridge Golf & Country Club (Eagle Ridge) is a corporation engaged in maintaining golf courses with around 112 rank-and-file employees by the end of 2005.
Respondent is the Eagle Ridge Employees Union (EREU or Union), organized by at least 20% of Eagle Ridge’s rank-and-file employees as required under Article 234(c) of the Labor Code.

On December 6, 2005, at least 20% of Eagle Ridge’s rank-and-file employees met, organized into the independent labor union named Eagle Ridge Employees Union (EREU), elected officers, and ratified their constitution and by-laws.
On December 19, 2005, EREU formally applied for registration before the Department of Labor and Employment (DOLE) Regional Office IV (RO IV), which was granted Registration Certificate No. RO400-200512-UR-003.
EREU subsequently filed a petition for certification election in Eagle Ridge, docketed as Case No. RO400-0601-RU-002.

Eagle Ridge opposed the certification election petition and filed a petition for cancellation of EREU’s registration certificate, docketed as RO400-0602-AU-003, alleging:

Misrepresentation and fraud concerning the constitution and by-laws, union membership count, and officers’ election.
The application declared 30 members, while minutes of the organizational meeting reflected only 26 members.
Discrepancy in ratification signatures (25 certified but 26 signatures appearing, implying forgery).
Five employees who attended the meeting later retracted their membership via affidavits, claiming unawareness and improper conduct of the meeting.

Eagle Ridge contended these retractions reduce the membership below the required 20% threshold (22 or 23 members).

Asserted procedural deficiencies in Eagle Ridge’s petition (lack of certification against forum shopping and unauthorized verification).
Explained discrepancies by stating four members joined after the organizational meeting but before registration application, raising membership to 30 by December 19, 2005.
Claimed the understatement by one member in ratification was a typographical error.
Argued the retraction affidavits lack credibility and could have been executed under duress or coercion, and do not affect the petition since withdrawal after filing of certification election petition does not affect Union’s status.
Presented union membership forms, joint affidavits affirming proper conduct of the organizational meeting, and affidavits by legal counsel.

The DOLE Regional Director initially ruled in favor of Eagle Ridge, ordering cancellation of EREU’s registration.
The Bureau of Labor Relations (BLR), headed by an Officer-in-Charge, affirmed this cancellation.
The BLR Director later reversed these rulings, reinstating EREU as a legitimate labor organization.
Eagle Ridge sought reconsideration, which was denied.
Eagle Ridge filed a petition for certiorari before the Court of Appeals (CA), which was dismissed due to procedural defects, particularly the lack of proper authorization for counsel’s signing of verification and certification against forum shopping.
Eagle Ridge’s motion for reconsideration before the CA was also denied despite submission of board resolution authorizing counsel.

Whether the Court of Appeals committed grave abuse of discretion in dismissing Eagle Ridge’s petition for certiorari and denying its motion for reconsideration on grounds of lack of authorization of its counsel to sign the verification and certification against forum shopping.

Whether there was fraud, misrepresentation, or false statement warranting cancellation of EREU’s certificate of registration based on the evidence on record.