G.R. No. L-48931 - Ilaw at Buklod ng Manggagawa vs. Director of Labor Relations

On June 24, 1976, within sixty days prior to the expiration (August 19, 1976) of an unregistered collective bargaining agreement between the Associated Labor Unions and the General Milling Corporation:

Ilaw at Buklod ng Manggagawa (IBM), a duly registered labor union, filed a petition for a certification election with the Ministry of Labor’s Regional Office No. 7 in Cebu City.
The filing was prompted by the impending expiration of the existing agreement, which created uncertainty over representation for the rank-and-file employees.

A med-arbiter, in his order dated October 12, 1976, granted the petition and ordered that a certification election be held among the company’s employees at Lapu-Lapu City within twenty days from notice:

The decision affirmed the right of a registered labor union to secure representation through a certification process.
The timely resolution of certification cases was emphasized by the statutory time limit provided under the Labor Code.

The Associated Labor Unions appealed the med-arbiter’s order to the Director of Labor Relations:

Instead of promptly deciding the appeal, the Director transferred the case record to the Trade Union Congress of the Philippines (TUCP), a federation of labor unions.
The referral was allegedly based on an arrangement between the Ministry of Labor and the TUCP, whereby cases involving TUCP member-unions were to be referred to the federation for possible settlement in conformity with its Code of Ethics.

The TUCP did not decide or settle the controversy, and after more than twenty months, on September 14, 1978, IBM filed a petition for mandamus before the Court:

IBM sought to compel the Director of Labor Relations to decide the appeal or, alternatively, to require the TUCP to return the record of the case.
IBM raised concerns about a potential conflict of interest, noting that the president of the TUCP is also the president of the Associated Labor Unions, although the TUCP clarified that its executive board would decide the dispute.

The Director of Labor Relations expressing his readiness to decide the appeal and calling for the prompt return of the case record from the TUCP.
The General Milling Corporation, in its comment, revealing that it had a registered collective bargaining agreement with the Associated Labor Unions, presumed to be a renewal of the earlier expiring agreement, which underscored the urgency behind the petition for certification election.
IBM’s allegation that its affiliation with the TUCP began only in 1978, long after the certification case had been referred, and its complaint that similar cases referred to the TUCP had been unduly delayed, amounting to a denial of labor justice.

Whether it was legal and proper for the Director of Labor Relations to refer the appeal in a certification election case to the TUCP:

Does such referral constitute an abdication, delegation, and relinquishment of the Director’s inherent adjudicatory functions as mandated by the Labor Code?
Is this act consistent with the statutory framework established for the expeditious resolution of labor disputes?

Whether the transfer of the original, official record of the certification election case from the Ministry of Labor’s custody to a private entity (the TUCP) was in conformity with the legal provisions regarding the handling of public records:

Can a private federation be entrusted with an official public record without compromising its integrity?
Does such a practice conflict with the rules on the irremovability of public records as set forth in the Rules of Court?