G.R. No. 205735 - Villena vs. Batangas II Electric Cooperative, Inc.

On 14 August 1986, without the general membership’s knowledge or approval, respondent Umali unilaterally “affiliated” the petitioner-union, Litton Mills Employees Association-Kapatiran (LMEA-K), with the National Union of Garments, Textile, Cordage and General Workers of the Philippines (GATCORD).
The affiliation was evidenced by a Pledge of Allegiance signed by the newly appointed shop steward, Norberto David, which was attested by GATCORD President Timoteo Aranjuez.
Mimeographed leaflets were distributed urging union members to continue affiliation with GATCORD, while simultaneously maligning the union’s legal counsel and certain elected officers.

A majority of the union’s members, numbering approximately 725 out of an estimated 1,100, opposed the affiliation.
The opposition was formally expressed through a statement, “Sama-Samang Kapasiyahan,” dated 18 August 1986, which also empowered petitioner Rogelio Abong to take action against Umali should the affiliation persist.

Despite the majority opposition, Umali proceeded with the affiliation, as further evidenced by a letter to Litton Mills, Inc. (LMI) dated 20 August 1986, printed on GATCORD letterhead and again attested by Timoteo Aranjuez.
On 24 August 1986, Abong and other union officers signed a letter accusing Umali of disloyalty and demanding his appearance at a meeting scheduled for 27 August 1986 to answer the charges.
Umali’s failure to attend the meeting led the majority of the union officers to vote for his impeachment, which was communicated to him by letter on 30 August 1986.
Petitioners later initiated administrative proceedings by lodging a complaint before the med-arbitrator of the Department of Labor and Employment, docketed as NCR-LRD-M-9-718-86, seeking a declaration of the impeachment’s validity, termination of Umali’s employment under the collective bargaining agreement (CBA), and the appointment of Abong as the new president.

LMI, in its letter dated 10 September 1986, conditioned any action on the union’s internal impeachment process by requiring that the dispute be first resolved with the Department of Labor and Employment pursuant to the CBA provisions.
The collective bargaining agreement specifically mandated compliance with labor requirements, limiting immediate remedial action without prior administrative process.

On 15 November 1986, Med-Arbiter Rasidali Abdullah ruled that issues regarding the union’s affiliation could not be resolved in the complaint and declared the impeachment of Umali as null and void due to lack of compliance with the union’s constitutional and by-law procedures.
The Med-Arbiter found that the absence of Umali in the investigation meeting could not legally constitute an admission of disloyalty.
The order highlighted that even assuming Umali acted to promote affiliation, his act did not equate to abandonment of union membership, and thus did not warrant removal under the union’s rules.

The union’s Constitution and By-Laws, specifically Section 5, Article IV, clearly prohibits affiliation with any labor federation, as joining such a federation is deemed as organizing or joining another union.
Umali’s unilateral affiliation with GATCORD not only violated these internal rules but also breached the terms of the existing CBA with LMI, which forbids modifications during its term unless proper notice is given.

Subsequent to these proceedings, a group led by petitioner Abong broke away from LMEA-K and formed the Litton Mills Workers Union.
A certification election subsequently resulted in the breakaway union being recognized as the collective bargaining agent for LMI, thereby rendering the impeachment and related issues moot.

Whether respondent Umali’s act of affiliating LMEA-K with GATCORD was conducted with the consent of the majority of the union membership or was a unilateral, unauthorized action.
Whether the impeachment of Umali, executed without full compliance with the union’s constitutional and by-law prescribed procedures—including providing adequate opportunity for defense—was legally valid.
Whether the petitioners’ subsequent prayer to terminate Umali’s employment with LMI under the union security clause of the CBA is sustainable given the procedural irregularities in the impeachment process and the breach of internal rules.
Whether the supervening fact of a new certification election, which resulted in the formation of a breakaway union recognized as the collective bargaining representative, renders the issues raised in the petition moot and academic.