Case Digest (G.R. No. 84433) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Alexander Reyes et al. v. Cresenciano B. Trajano et al. (G.R. No. 84433, June 02, 1992), 141 employees of Tri-Union Industries Corporation who were members of the Iglesia ni Kristo (INK) filed a special civil action for certiorari after having their votes excluded in a certification election held on October 20, 1987. The Bureau of Labor Relations (BLR), through Med-Arbiter Paterno Adap and Officer-in-Charge Cresenciano B. Trajano, denied these petitioners the right to vote on the ground that they were not members of any labor organization and had abstained from prior elections due to religious beliefs. Of 348 qualified voters, only 240 cast ballots: 95 for the Tri-Union Employees Union-OLALIA (TUEU-OLALIA), 1 for the Trade Union of the Philippines and Allied Services (TUPAS), 1 “No Union,” 1 spoiled, and 141 “challenged” (the INK ballots). On December 21, 1987 the Med-Arbiter certified TUEU-OLALIA as the exclusive bargaining agent, a decision affirmed by OIC Trajano on July 2 Case Digest (G.R. No. 84433) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Certification election background
- The Bureau of Labor Relations (BLR) authorized a certification election on October 20, 1987 among Tri-Union Industries Corporation employees to determine the exclusive bargaining representative.
- Two labor organizations competed: Tri-Union Employees Union-Organized Labor Association in Line Industries and Agriculture (TUEU-OLALIA) and Trade Union of the Philippines and Allied Services (TUPAS).
- Voter composition and challenged ballots
- Of 348 qualified voters, 240 cast ballots; among them were 141 employees who were members of Iglesia ni Kristo (INK).
- Ballots offered three choices: TUPAS, TUEU-OLALIA, or “NO UNION.” The final tally recorded 95 for TUEU-OLALIA, 1 for TUPAS, 1 NO UNION, 1 spoiled, and 141 challenged (the INK votes).
- At the pre-election conference, the contending unions agreed to exclude the 141 INK ballots on grounds that petitioners were not union members and had not participated previously.
- Administrative proceedings
- The INK members filed a petition with the Med-Arbiter to cancel the election, alleging unfairness and disenfranchisement. TUEU-OLALIA opposed, arguing lack of legal personality on religious grounds.
- By Order (December 21, 1987), the Med-Arbiter denied the petition, certified TUEU-OLALIA, and held that petitioners had no personality to challenge as they were not parties to the initial petition.
- On appeal, OIC Assistant Labor Secretary Trajano (Decision of July 22, 1988) upheld the Med-Arbiter, emphasizing petitioners’ lack of union status and non-participation in prior elections.
- Supreme Court intervention
- The INK members filed a special civil action for certiorari to annul the OIC’s Decision.
- The Solicitor General supported the petitioners; the NLRC filed a comment urging respect for all employees’ rights to self-organization.
Issues:
- Whether non-union employees (INK members) possess legal personality and the right to vote in a certification election.
- Whether the exclusion of INK ballots by the Med-Arbiter and the OIC constituted grave abuse of discretion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)