G.R. No. L-15459 - United States Lines Co. vs. Court of Industrial Relations

The Associated Watchmen & Security Union (PTWO) filed a petition on or about February 21, 1956, with the Court of Industrial Relations.
The petition alleged that the United States Lines Company, a shipping corporation, employed watchmen who operated aboard its vessels while docked or staying in Philippine waters.
The Union contended that these watchmen formed an appropriate and separate bargaining unit composed of approximately 30 employees, over which the Union held the majority membership.
The petition prayed for the certification of the Union as the collective bargaining agent for the specified unit.

The Maligaya Ship Watchmen Agency intervened in the case.
The case was heard jointly with others: Cases Nos. 329-MC and 332-MC (filed by the Union against American President Lines and Macondray & Co., respectively) and Case No. 10-IPA (involving the United States Lines Company).
During the proceedings, the Union amended its petition to limit the certification unit exclusively to the Port of Manila, specifically seeking certification for the City of Manila.

On December 20, 1956, the Court of Industrial Relations rendered a decision ordering the Department of Labor to conduct a certification election pursuant to Section 12 of Republic Act No. 875 and its approved rules.
The order specified detailed procedures for the election, including:

The use of payrolls from various ships showing worked service by watchmen or security guards from January 18, 1956.
The eligibility criteria, which allowed vote casting by watchmen present during the specified period, even if they were temporarily on leave, sick, or on vacation; however, exclusions were made for those who had quit, been discharged for cause and not reinstated, or were on strike without entitlement to reinstatement.
Provisions for vote impounding in cases where charges of discriminatory discharge were pending.

The directives required the Department of Labor to record the reasons and rulings where challenges were made and to transmit the election results to the Court within the legal time frame.

On January 2, 1959, the Department of Labor conducted the certification election among the ship watchmen.
The Maligaya Ship Watchmen Agency obtained the requisite majority vote.
Subsequently, on January 23, 1959, the Court of Industrial Relations issued an order certifying the Agency as “the sole and exclusive representative of all employees and laborers of the United States Lines, for the purpose of collective bargaining with respect to rates of pay, wages, hours of employment and other conditions of employment.”

The United States Lines Company challenged the certification order, arguing that it improperly expanded the collective bargaining unit beyond the intended group.
Specifically, the Company claimed that while the amended petition was limited to watchmen on vessels in the Port of Manila, the order encompassed all employees and laborers of the United States Lines, both in Manila and in other parts of the Philippines.
On January 2, 1959, the Company filed a motion for reconsideration requesting that the order’s language be modified to certify only “all watchmen rendering service on the vessels of the United States Lines in the Port of Manila.”
Although not opposed by the intervenors or the Union, the Court of Industrial Relations, sitting en banc, denied the motion for reconsideration on February 19, 1959, stating that there was insufficient justification to change or modify the order.

Petitioner (the Company) maintained that the certification order expanded the collective bargaining unit beyond the narrow group of watchmen stipulated in the petition and affirmed by the evidence.
The Union (PTWO) argued that the certification order correctly referred only to the watchmen in the certified unit and did not include any additional employees or laborers.
The lower court, in its defenses, insisted that the order did not intend to expand the bargaining unit and was consistent with the pleadings and evidentiary record, as evidenced by statements made during the hearings.

The Supreme Court noted that the certification election was explicitly limited to the watchmen working on vessels docked or operating in the Port of Manila.
Recognizing that the dispute over the purported expansion of the collective bargaining unit had become moot when the facts were properly construed, the Supreme Court affirmed the lower court’s order.
The certification was thus upheld strictly for the watchmen in the port, and no special pronouncement regarding costs was made.

Whether the certification order of January 23, 1959, should be interpreted as having expanded the bargaining unit to include all employees and laborers of the United States Lines Company.

Petitioner argued that the language of the order was contrary to the pleadings and evidence by including employees beyond the watchmen in the Port of Manila.
The lower court and the Union contended that the order was limited to the watchmen working on vessels in the Port of Manila, in line with the original petition and evidentiary record.

Whether the motion for reconsideration, aimed at restricting the scope of the bargaining unit, should have been granted.

The Company filed the motion seeking to change the wording of the order so that it exactly conformed with the specific unit of watchmen as originally petitioned.
The Court of Industrial Relations denied the motion, maintaining its original interpretation.