G.R. No. L-7649 - San Beda College vs. Court of Industrial Relations

On 16 December 1952, the National Labor Union, representing over 30 employees of San Beda College, submitted demands for wage increases and other concessions.
The management of San Beda College refused to grant the union’s demands.

On 20 January 1953, shortly after the demand was made, the National Labor Union filed a petition with the Court of Industrial Relations seeking that the demands be granted retroactively from 16 December 1952 (Annex A).
On 24 January 1953, San Beda College moved to dismiss the petition on the ground that approximately 30 out of 45–46 members of the union had withdrawn their membership, allegedly reducing the number of petitioning members below the required 30 (Annex B).

Evidence showed that several withdrawals (Exhibit 1) occurred in the afternoon of 20 January 1953, after the petition had been filed at 9:15 a.m.
The Court ruled that once jurisdiction is attached by the filing of the petition, subsequent withdrawal of union members cannot divest the court of its jurisdiction.

On 10 August 1953, San Beda College filed a motion for reconsideration claiming:

On 28 September 1953, San Beda College moved for rehearing on its motion to dismiss and sought to amend its grounds to claim that the unsatisfied demands did not constitute an industrial or agricultural dispute under section 4, Commonwealth Act No. 103, as amended by Acts Nos. 254 and 559 (Annex D).
On 5 October 1953, Associate Judge V. Jimenez Yanson denied the motion for rehearing because the previous ground had already been considered and denied.

On 12 February 1954, a motion for rehearing regarding the jurisdiction issue was again denied, and the case was set for hearing on its merits (Annex H).
On 20 February 1954, a motion for reconsideration was filed on the same grounds and was ultimately denied by the Court en banc on 9 March 1954 (Annex I and Annex J).

San Beda College elevated the case by filing a petition for a writ of certiorari seeking:

Reversal and setting aside of the orders of 1 August 1953, 12 February 1954, and 9 March 1954.
It argued that without proper jurisdiction the proceedings were premature—unless the jurisdictional barrier was resolved.

The respondent labor union admitted to most allegations except those concerning business nature and profit generation where it maintained that:

San Beda College is engaged in educational and residential services for young men, which inherently aligns with non-industrial pursuits.
The institution, operated by the Benedictine Order, is not primarily profit-driven, thereby falling outside the ambit of industrial employment disputes.

Whether the Court of Industrial Relations had jurisdiction over the petition given that, at the time of filing, the union met the minimum membership requirement, despite subsequent withdrawals.
Whether the subsequent withdrawal of union members could divest the court of its jurisdiction once the petition was filed.

Whether the dispute between San Beda College and its employees should be considered an industrial dispute under Commonwealth Act No. 103, as amended by Acts Nos. 254 and 559.
Whether the nature of San Beda College’s operations—being an educational institution managed by a religious order and not primarily profit-driven—excludes it from being classified as an industrial enterprise.

Whether the absence of evidence regarding the profit-oriented nature of the college affected the court’s capacity to determine if the dispute effectively arose from industrial employment.
Whether San Beda College’s claim of non-industrial operations could be substantiated by evidence regarding its educational and boarding functions.