G.R. No. 205743 - Turla vs. Heirs of Dayrit

On December 27, 1994, a petition for certification election was filed by the Alliance of Nationalist Genuine Labor Organization-Kilusang Mayo Uno (ANGLO-KMU) concerning the representation of rank and file employees of Cebu Shipyard and Engineering Work, Inc., a company employing roughly 400 workers.
The petition alleged that ANGLO-KMU qualified as a legitimate labor organization and claimed that it was supported by more than 25% of the employees in the bargaining unit.
It contended that filing was timely as it fell within the 60-day period preceding the expiry of the existing collective bargaining agreement (CBA), set to expire on December 31, 1994.
The petition further maintained that no legal bar prevented ANGLO-KMU from being certified as the sole and exclusive bargaining agent of all rank and file employees.

On January 2, 1995, the Med-Arbiter issued an order requiring ANGLO-KMU to present documentary proof of having created a local chapter in the appropriate bargaining unit.
The documents specified included a charter certificate, the constitution and by-laws, a statement on the set of officers, and the local’s books of accounts—each to be properly certified.
The order set a five-day deadline for compliance, warning that failure to comply would result in the dismissal of the petition.

On January 9, 1995, the forced-intervenor NFL moved to dismiss the petition, arguing that ANGLO-KMU lacked legal personality at the time of filing due to the absence of necessary documentary requirements.
NFL contended that for a local or chapter to be considered a legitimate labor organization, its charter certificate, constitution and by-laws, officer list, and books of accounts must be submitted to the Bureau of Labor Relations (BLR) or the Industrial Relations Division at the time of petition filing.
It further argued that the number of consent signatures (120) did not meet the required 25% threshold, particularly after noting discrepancies such as one signature dispute and several retractions.

On January 16, 1995, NFL supplemented its motion to dismiss by submitting certifications from the Regional Office and the BLR, further asserting that the required documents were submitted only on January 6, 1995—after the expiration of the freedom period (December 31, 1994).
On February 15, 1995, ANGLO-KMU filed its opposition to NFL’s motion to dismiss, arguing that the submission of the mandatory documents had cured any defect present at the time of filing and that the number of supporting signatures satisfied the legal requirement.
NFL reiterated its arguments in a reply filed on February 20, 1995, emphasizing the absence of legal personality at the time of filing and alleging misrepresentation and fraud in the procurement of the supporting documents.

The Med-Arbiter, on March 13, 1995, issued a resolution dismissing the petition for certification election, having found that the submission of the required documents establishing a local chapter was made only after the allowable filing period.
ANGLO-KMU appealed the Med-Arbiter’s dismissal, maintaining that it was a legitimate labor organization at the time of filing and that any defects were remedied by the subsequent submission of the necessary requirements.
On August 8, 1995, Undersecretary Bienvenido E. Laguesma, under the authority of the Secretary of Labor and Employment, set aside the Med-Arbiter’s resolution and issued a new order, finding that ANGLO-KMU had complied with the registration requirements at the time of the petition filing.

The National Federation of Labor (NFL) filed a petition for certiorari under Rule 65, challenging the resolution of Undersecretary Laguesma.
NFL alleged that the resolution was issued in disregard of existing laws and jurisprudence and that there was grave abuse of discretion in applying precedent cases, notably Fur v. Laguesma.
Rather than ruling on the substantive merits of the petition, the Supreme Court chose the opportunity to clarify the proper procedural rules for reviewing decisions or rulings of the Secretary of Labor under the Labor Code and its implementing rules.

Whether the subsequent submission of mandatory documentary requirements, after the expiration of the freedom period, can cure the defect of lacking legal personality at the time of filing.
Whether ANGLO-KMU, as the alleged petitioner, had a legal personality to file the petition for certification election when it was filed.
Whether the decision issued by Undersecretary Laguesma improperly relied on the ruling in Fur v. Laguesma in reaching its conclusion.
Whether the administrative decisions of the NLRC and the Secretary of Labor, though declared final and executory under the Labor Code, are subject to judicial review via a petition for certiorari under Rule 65.
Whether the proper venue for such petitions, considering the doctrine on the hierarchy of courts, is exclusively the Supreme Court or initially the Court of Appeals.