Facts:

The case involves Alfonso Umali, representing 201 members of the Independent Employees Union, as the petitioner against Primitivo Lovina, the Secretary of Labor of the Philippines, as the respondent. The events leading to this case began on November 25, 1948, when 201 employees of the Jai Alai Corporation organized themselves into a union named the "Independent Employees Union." The union's objectives were aligned with those outlined in Section 2 of Commonwealth Act 213. On December 29, 1948, the union submitted its constitution and by-laws to the Department of Labor. Following this, on January 7, 1949, the union's president wrote to the Secretary of Labor requesting prompt action on their registration application. In response, the Secretary of Labor communicated with the president of the existing Jai Alaistas Union of Employees, granting them an extension to hold elections, with a warning that if they failed to do so, he would register the Independent Emplo...

Facts:

1. Formation of the Union: On 25 November 194#, 201 employees of the Jai Alai Corporation of the Philippines organized themselves into the "Independent Employees Union" (IEU), with objectives aligned with Section 2 of Commonwealth Act 213.
2. Submission of Documents: On 29 December 194#, the IEU filed its constitution and by-laws with the Department of Labor.
3. Request for Action: On 7 January 1949, the IEU President wrote to the Secretary of Labor, requesting immediate action on their pending application for registration.
4. Extension Granted to Competing Union: On the same date, the Secretary of Labor granted the Jai Alaistas Union of Employees (a registered union) an extension until 15 January 1949 to hold an election, warning that failure to do so would result in the registration of the IEU.
5. Failure to Hold Election: The Jai Alaistas Union failed to hold the election by the extended deadline.
6. Refusal to Register IEU: Despite the Secretary of Labor's promise to register the IEU if the election was not held, he refused to do so, citing a policy of allowing only one union per company.
7. Formal Application Filed: On 3 February 1949, a formal application for registration and permit was filed on behalf of the IEU by the National Labor Union.
8. Respondent's Justifications: The Secretary of Labor defended his refusal to register the IEU, citing:
   • Lack of a formal application (initially).
   • Failure of the IEU to complete a required questionnaire.
   • His policy of recognizing only one union per company.
   • No fixed period under Commonwealth Act 213 for completing investigations.
   • Discretion to issue or deny permits.

Issue:

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Ruling:

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Ratio:

1. Duty to Register: Under Section 3 of Commonwealth Act 213, the Secretary of Labor is mandated to register a labor union and issue a permit if the union’s objectives are lawful and do not undermine the government or violate Philippine laws.
2. Investigation Requirement: The investigation required by law need not be limited to a questionnaire. The Secretary can use other means to gather necessary information.
3. No Discretion to Deny Registration: The Secretary of Labor does not have unlimited discretion to deny registration and permits. His actions must be based on the findings of a proper investigation and compliance with the law.
4. Policy of One Union Per Company: This policy is not grounded in Commonwealth Act 213 and cannot be used to deny registration to a legitimate labor union.
5. Mandamus as a Remedy: Since the Secretary of Labor neglected a duty specifically enjoined by law, and there was no other plain, speedy, and adequate remedy, mandamus was the appropriate remedy.