Title
La Union Labor Union vs. Philippine Tobacco Flue-Curing and Redrying Corporation
Case
G.R. No. L-14087
Decision Date
Jun 30, 1960
A labor union sought wage differentials via the Wage Administration Service, but the Supreme Court ruled the WAS lacked authority without a written arbitration agreement, voiding its decision.
A

Case Digest (G.R. No. 98695)

Facts:

La Union Labor Union v. Philippine Tobacco Flue-Curing & Redrying Corporation, G.R. No. L-14087, June 30, 1960, the Supreme Court En Banc, Montemayor, J., writing for the Court. The appeal challenged a decision of the Court of First Instance of La Union in Civil Case No. 1203 (May 27, 1958) ordering the issuance of a writ of mandatory injunction directing the respondent to submit payrolls and awarding attorney’s fees and costs.

The dispute began when La Union Labor Union filed Case No. 867-V in the Court of Industrial Relations on May 12, 1953 against the Philippine Tobacco Flue-Curing & Redrying Corporation (the Tobacco Corporation) over working conditions and wages. On July 7, 1954 the parties executed an agreement settling certain matters but containing a proviso that “all other points not covered by this agreement … such as … wage differentials … will be presented to the Wage Administration Service for adjudication.” The Industrial Court approved that agreement on July 10, 1954, terminating the case.

Pursuant to that proviso, the Union filed claims for wage differentials with the Wage Administration Service (WAS) on February 26, 1955 and reiterated them by counsel on March 14, 1956 to the Secretary of Labor through WAS. The WAS transmitted the matter to the Regional Labor Administrator on April 14, 1956, who on May 25, 1956 instructed Regional Labor Attorney Fructuoso F. Alban to investigate and decide the case. After investigation, Atty. Alban issued a decision in WAS Case No. 180 on July 16, 1956 granting certain wage differentials and ordering the respondent to submit payrolls for 1954–1956 within ten days.

When the Tobacco Corporation did not submit payrolls, the Union sued in the Court of First Instance of La Union on August 3, 1957 (Civil Case No. 1203), seeking (1) a writ of mandatory injunction compelling submission of the payrolls to the Regional Labor Attorney and (2) issuance of execution on the WAS award after computation. The Tobacco Corporation answered on August 30, 1957, contending that Atty. Alban’s decision was null for lack of authority. The Court of First Instance rendered judgment on May 27, 1958 in favor of the Union, ordering issuance of the writ and attorney’s fees. The Tobacco Corporation appealed to the Supreme Court (G.R. No. L-14087).

Issues:

  • Did the Wage Administration Service and its agents have authority to render a binding decision in wage-differential claims in the absence of a written agreement by the parties to submit the dispute to arbitration?
  • Did the Court of First Instance properly issue a writ of mandatory injunction directing respondent to submit payrolls and enforce the WAS decision?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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