Case Digest (G.R. No. L-18170)
Facts:
National Brewery & Allied Industries Labor Union of the Philippines v. San Miguel Brewery, Inc., et al., G.R. No. L-18170, August 31, 1963, the Supreme Court, Regala, J., writing for the Court. The appellant, National Brewery & Allied Industries Labor Union of the Philippines (the union), was the certified bargaining representative of all regular daily‑rated workers and route helpers of San Miguel Brewery, Inc. On October 2, 1959 the union and the company executed a collective bargaining agreement that expressly provided: the company would deduct a “union agency fee” from the wages of non‑members provided those workers authorized the deduction in writing or a competent court directed the company to make such deductions (Art. II, Sec. 4).Alleging it had obtained benefits for all employees and that the Independent San Miguel Brewery Workers' Association and other non‑member employees refused to pay the agency fee and that the company refused to deduct and remit such fee, the appellant sued for collection of the agency fees on November 17, 1960 in the Court of First Instance of Manila.
On motion of the Independent Association the trial court dismissed the complaint. The trial court held that the Industrial Peace Act (Republic Act No. 875) did not authorize collection of agency fees; that quasi‑contract (unjust enrichment) did not apply because the union had not alleged that P4.00 represented the actual expense of representation; and that agency principles were inapplicable because there was no agreement between the union and individual employees obliging them to pay. The court denied the union’s motion for reconsideration, and the union appealed to the Supreme Court.
The central question presented, a question of first impression in this jurisdiction, was whether a union agency fee is a permissible form of union security under Secti...(Pro-only)
Issues:
- Under Section 4(a)(4) of the Industrial Peace Act (Republic Act No. 875), is an agreement obliging the employer to deduct a union agency fee from non‑members a permissible form of union security?
- Can the union collect agency fees from non‑members on the theory of quasi‑contract (unjust enrichment) under Article 2142 of the Civil Code?
- Can the union collect agency fees from non‑members on the basis of the law of agency (presumed com...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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