Title
Umali vs. Lovina
Case
G.R. No. L-2771
Decision Date
Apr 29, 1950
The Philippine court mandates the Secretary of Labor to register the Independent Employees Union and issue its permit, finding no valid grounds for denial.
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Case Digest (G.R. No. L-2771)

Facts:

  • Alfonso Umali represented 201 members of the Independent Employees Union as the petitioner.
  • Primitivo Lovina, the Secretary of Labor of the Philippines, was the respondent.
  • On November 25, 1948, 201 employees of the Jai Alai Corporation formed the Independent Employees Union.
  • The union's objectives aligned with Section 2 of Commonwealth Act 213.
  • The union submitted its constitution and by-laws to the Department of Labor on December 29, 1948.
  • On January 7, 1949, the union's president requested prompt action on their registration application.
  • The Secretary of Labor communicated with the Jai Alaistas Union, granting them an extension to hold elections.
  • The Secretary warned that if elections were not held, he would register the Independent Employees Union.
  • The Jai Alaistas Union failed to hold elections by the deadline.
  • The Secretary of Labor refused to register the Independent Employees Union, citing the need for a formal application and further investigation.
  • The petitioner argued that the refusal was unjustified and sought a writ of mandamus from the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the petitioner, granting the writ of mandamus.
  • The Court determined that the Secretary of Labor neglected his duty to regist...(Unlock)

Ratio:

  • The Court's decision was based on the interpretation of Commonwealth Act 213, which requires the Secretary of Labor to investigate upon receiving a registration application.
  • The Secretary had previously acknowledged the pending application and indicated that registration would occur if the Jai Alaistas Union failed to hold elections.
  • The Court found that the Secretary's failure to complete the invest...continue reading

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