Title
Johnson and Johnson Labor Union vs. Director of Labor Relations
Case
G.R. No. 76427
Decision Date
Feb 21, 1989
Union constitution mandates financial aid for unjustly terminated members; court upheld Pili's entitlement, ruling union's refusal discriminatory and enforceable without individual member consent.
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Case Digest (G.R. No. 76427)

Facts:

  1. Union Constitution Provision: The petitioner-union's Constitution and By-Laws, Article XIII, Section 5, provides financial aid to members suspended or terminated without reasonable cause. The aid is funded by compulsory contributions of P0.75 per member weekly.
  2. Private Respondent's Dismissal: Oscar Pili, a union member, was dismissed by Johnson & Johnson (Phil.) Inc. on May 6, 1985, for failing to disclose a relative in the company, violating company policies.
  3. Complaint for Financial Aid: On July 1985, Pili filed a complaint against the union officers for refusing to grant him financial aid despite demands. The union countered that aid is only for terminations without reasonable cause and that the executive board has the prerogative to determine the reasonableness of the cause.
  4. Union Resolution: The union, in a general membership meeting, resolved not to extend financial aid to Pili.
  5. Unfair Labor Practice Case: Pili filed a case for unfair labor practice and illegal dismissal against his employer on August 26, 1985.
  6. Med-Arbiter's Decision: On September 27, 1985, Med-Arbiter Anastacio L. Bactin dismissed Pili's complaint against the union for lack of merit.
  7. Public Respondent's Decision: On April 17, 1986, Director Cresenciano B. Trajano reversed the Med-Arbiter's decision, ordering the union to pay Pili P0.75/week per member from the time of his termination until he finds new employment, provided his illegal dismissal case is resolved in his favor.
  8. Modification of Decision: On August 19, 1986, the public respondent modified the decision, ordering immediate payment to Pili without prejudice to a refund if his case is resolved against him.
  9. Writ of Execution: On December 18, 1986, a writ of execution was issued to collect P20,520 from the union.
  10. Petition for Review: The union filed a petition for review on December 24, 1986, alleging grave abuse of discretion, violation of law, and deprivation of due process.

Issue:

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Ruling:

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Ratio:

  1. Self-Executory Provision: The financial aid provision in the union's constitution is clear and does not require individual payroll authorizations. The compulsory contributions are intended for mutual assistance among members.
  2. Interpretation of Union Constitution: The union constitution is a binding covenant, and its interpretation is not left solely to the union or its officers. Quasi-judicial agencies have the authority to interpret such provisions.
  3. Due Process: The union members were adequately represented by their officers, and the suit to enforce the union constitution did not require impleading each member individually.
  4. Non-Discrimination: The union's refusal to grant financial aid to Pili while granting it to another member in a similar situation (Jerwin Taguba) was discriminatory and unjust.


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