G.R. No. 67485 - National Congress of Unions in the Sugar Industry of the Philippines vs. Trajano

A petition for certification election was initiated by the private respondent union, FUR-TUCP, amidst ongoing labor disputes.
On July 23, 1982, the Acting Med-Arbiter, Pacifico V. Militante, dismissed the petition for certification election due to the existence of a pending bargaining deadlock.
Subsequently, on August 25, 1982, the private respondent union appealed the dismissal to the Bureau of Labor Relations in Manila.
The Bureau, through Director Cresenciano B. Trajano, rendered a decision on September 30, 1982, setting aside the Med-Arbiter’s dismissal order and remanding the case to Regional Office VI in Iloilo City for evidentiary hearings.
On May 2, 1983, Med-Arbiter Demetrio Correa issued an order in LRD Case No. 4293 giving due course to the petition and ordering that a certification election be held within 20 days from receipt of the order.

During the pendency of these administrative proceedings, on September 10, 1983, a collective bargaining agreement (CBA) was executed between the management of National Sugar Refineries Co., Inc. and the petitioner union.
The CBA, which later provided substantial benefits, brought into question the authority of the originally certified exclusive bargaining agent of Calinog Refinery Corporation.
Notably, before the certification election petition was addressed, a petition for deadlock in collective bargaining was filed on June 21, 1982, which was subsequently submitted to compulsory arbitration and docketed as RAB Case No. VI-0220-82.
The existing deadlock and the subsequent formation of a CBA posed conflicting circumstances regarding the filing and conduct of a new certification election.

In response to the order of Med-Arbiter Correa, the petitioner union (NACUSIP-TUCP) filed an appeal with the Bureau of Labor Relations.
On November 18, 1983, Director Trajano of the Bureau of Labor Relations rendered a decision affirming, with qualifications, the Med-Arbiter’s order that ordered a certification election, remarking on the change in the support base of the existing exclusive bargaining representative.
The petitioner filed a motion for reconsideration on December 6, 1983, which was ultimately denied by Director Trajano on March 21, 1984, thereby reaffirming the decision for a certification election.
On December 10, 1984, and in view of urgent circumstances, the Court issued a temporary restraining order to enjoin the respondents from conducting the scheduled certification election.

Petitioner NACUSIP-TUCP contended that Director Trajano had committed grave abuse of discretion and acted beyond his jurisdiction by ordering a certification election despite the pending bargaining deadlock.
The petitioner argued that the decision disregarded Section 3 of the Rules Implementing Batas Pambansa Blg. 130, which bars the filing of a certification election petition during the existence of a bargaining deadlock.
The Solicitor General joined in the contention, asserting that the Director’s action was arbitrary and contrary to the statutory mandate, especially given the concurrent existence of a valid collective bargaining agreement with a three-year lifespan.
The dispute centered on whether a petition for certification election could lawfully be entertained when a bargaining deadlock had already been submitted to arbitration—a question of paramount importance given the intended stability in labor-management relations.

Whether a petition for certification election may be validly filed and entertained during the pendency of a bargaining deadlock that has been submitted to arbitration or conciliation.
Whether the actions of Director Trajano in setting aside the dismissal order of the Acting Med-Arbiter and subsequently ordering a certification election were in conformity with the mandatory provisions of Section 3 of the Rules Implementing Batas Pambansa Blg. 130 and the Omnibus Rules Implementing the Labor Code.
Whether such actions, by disregarding the “deadlock bar” rule and the existence of a concluded CBA, constitute grave abuse of discretion and arbitrary exercise of administrative authority.