G.R. No. L-44096 - People vs. Morales y Alas

George & Peter Lines, Inc. is a domestic shipping corporation with a sizeable workforce.
Associated Labor Unions (ALU) is a duly registered labor organization with the Ministry of Labor.

On July 6, 1978, ALU filed a Petition for Direct Certification with Region VII, Cebu City, seeking recognition as the sole and exclusive bargaining representative for all rank and file employees of George & Peter Lines, Inc.
The petition was premised on the absence of any existing labor union organized among the employees of the petitioner.

The petitioner contended that ALU did not represent the majority of its employees.
Evidence was presented that more than 80% of the licensed and unlicensed crew members denied union membership and expressed no intention of joining any.
As a countermeasure, on August 17, 1978, the petitioner filed a Petition for Certification Election to definitively resolve the question of representation by allowing the employees to choose their sole bargaining agent.

On August 25, 1978, a Med-Arbiter issued an Order directly certifying ALU as the exclusive bargaining agent.
The Med-Arbiter’s opinion was based on the determination that the majority membership status of any union is fixed at the time of filing the petition, implying that subsequent changes (such as membership withdrawal) would be immaterial.

After the petitioner’s opposition and the retraction of membership by about 80% of the employees, the case records were forwarded to the Director of the Bureau of Labor Relations.
On February 5, 1979, the BLR Director modified the Med-Arbiter’s Order by directing that a certification election be held among the employees.
A reconsideration petition was filed by ALU, but the BLR Director, on May 31, 1979, found the union’s majority status doubtful due to the withdrawal of membership and ordered a pre-election conference followed by a certification election.

ALU submitted a Second Motion for Reconsideration arguing that its majority status had been adequately proven during the Med-Arbiter’s hearing.
The BLR Director, on August 13, 1979, reconsidered the previous resolution and again issued an Order directly certifying ALU as the sole bargaining agent.

Petitioner contested the BLR Director’s reversal of resolutions by questioning the legality and fairness of bypassing a certification election.
The petitioner argued for the necessity of a certification election to reflect the true will of its employees, emphasizing that the employees had a constitutional right to choose their representative.

A written manifestation was presented, signed by approximately 80% of the employees, formally retracting their membership from ALU after ALU filed its petition for direct certification.
ALU, in turn, claimed that the retractions were the result of managerial pressure, thus contesting the validity of the employee withdrawals as a true reflection of their intent.

Whether the Director of the Bureau of Labor Relations committed grave abuse of discretion by abruptly reversing his earlier resolutions that mandated holding a certification election.
Whether the employees of George & Peter Lines, Inc. are constitutionally entitled to choose their sole and exclusive bargaining representative through a certification election.
Whether the petitioner (George & Peter Lines, Inc.) is entitled to file a petition for a certification election in this context.