Title
General Maritime Stevedores' Union of the Philippines vs. South Sea Shipping Line
Case
G.R. No. L-14689
Decision Date
Jul 26, 1960
A case involving a petition for certification election filed by the General Maritime Stevedores' Union of the Philippines challenges the validity of a collective bargaining agreement and seeks the opportunity to prove majority representation among workers and employees of a shipping line, leading to a remand for the petition to be entertained and a certification election to be held.
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Case Digest (G.R. No. L-14689)

Facts:

  • The case "General Maritime Stevedores' Union of the Philippines v. South Sea Shipping Line" was decided by the Supreme Court on July 26, 1960, under G.R. No. L-14689.
  • Petitioners included the General Maritime Stevedores' Union (GMSU) and others, who contested the dismissal of their petition for a certification election by the Court of Industrial Relations (CIR).
  • A certification election held on April 15 and June 10, 1955, resulted in the United Seamen's Union of the Philippines (USUP) being certified as the exclusive bargaining representative for employees of South Sea Shipping Lines.
  • A collective bargaining agreement was signed on June 28, 1957, between USUP and the Shipping Line, valid for two years with an automatic renewal clause.
  • On April 30, 1958, GMSU filed a petition for a certification election, asserting representation of 10% of unlicensed crew members and claiming no election had occurred in the previous twelve months.
  • The Shipping Line maintained neutrality, while USUP sought to dismiss GMSU's petition, arguing that the existing collective bargaining agreement barred such an election.
  • The CIR granted USUP's motion to dismiss based on the "contract-bar rule," prompting GMSU to seek certiorari for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the CIR's dismissal of GMSU's petition for a certification election, affirming its validity.
  • The Court noted the automatic renewal of the collective bargaining agreement, which could significantly extend its duration.
  • The case was remanded to the CIR to conduct a certif...(Unlock)

Ratio:

  • The decision was grounded in the "contract-bar rule," which permits a collective bargaining agreement of reasonable duration to prevent certification elections.
  • The Court emphasized ...continue reading

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