G.R. No. L-43760 - Philippine Association of Free Labor Unions vs. Bureau of Labor Relations

The certification election was held on February 27, 1976, to determine the sole and exclusive bargaining representative of the employees of Philippine Blooming Mills, Company, Inc.
Two unions were involved: the petitioner, Philippine Association of Free Labor Unions (PAFLU), and the respondent, National Federation of Free Labor Unions (NAFLU).
The vote count showed that NAFLU obtained 429 votes while PAFLU obtained 414 votes.
In addition, four votes were cast by employees who expressed a preference for no union.
Seventeen ballots were identified as spoiled, with PAFLU contending that at least ten of these were intended for their union.

The Rules and Regulations implementing the Labor Code of the Philippines governed the election process, specifically stating that a majority of the valid votes cast shall certify a union as the exclusive bargaining agent.
The certification was executed by the respondent Director of Labor Relations, Carmelo C. Noriel, who based his decision solely on the count of valid votes, in line with the implementing rules.
The petition by PAFLU argued that the spoiled ballots should have been added to the vote total, allegedly altering the outcome in favor of PAFLU.

PAFLU claimed that the doctrine derived from an earlier decision (Allied Workers Association of the Philippines v. Court of Industrial Relations) required the inclusion of spoiled ballots in the determination of the vote majority.
The petitioner alleged that failure to count these spoiled ballots amounted to a grave abuse of discretion on the part of the respondent Director.
PAFLU further asserted that such exclusion contravened the law under Article 256 of the Labor Code, arguing that a proper accounting of all ballots would have given them a vote majority (424 versus 429).

The dispute arose under the framework of the present Labor Code, which came into effect on November 1, 1974, along with its implementing rules promulgated by the Secretary of Labor.
The prior legal regime, embodied in the Industrial Peace Act and its corresponding rules, had been superseded by the current Labor Code and its regulations.
The implementing rules clearly prescribed that only "valid votes" were to be considered in the certification process, leaving no room for the inclusion of spoiled ballots.

Whether the exclusion of spoiled ballots in determining the majority of votes cast during the certification election is consistent with the rules and regulations implementing the present Labor Code.

Does the counting of only valid ballots, as mandated by the Rules and Regulations, preclude the inclusion of spoiled ballots even if evidence suggests that some were intended for PAFLU?

Whether the respondent Director of Labor Relations, Carmelo C. Noriel, committed a grave abuse of discretion by not considering the spoiled ballots in his certification decision.

Is there any conflict between the directive in the current implementing rules and the earlier Allied Workers Association case regarding the counting of spoiled ballots?

Whether the doctrine of giving controlling weight to the contemporaneous construction of a statute by executive officials applies in this situation.

Should the interpretation of the certification process made by the Department of Labor be respected as the proper construction of the Labor Code?