G.R. No. L-12222 - University of San Agustin vs. Court of Industrial Relations

A petition for review was filed challenging an order and resolution of the Court of Industrial Relations.
The order dated January 2, 1957, declared that the Court had jurisdiction over the controversy and ordered the case be referred for the required preliminary investigation.
The controversy arose from a complaint for unfair labor practice filed by the Philippine Association of College and University Professors against the University of San Agustin.

The petitioner, University of San Agustin, is an educational institution managed by a religious non-stock corporation dedicated exclusively to religious and educational purposes.
The respondent, Philippine Association of College and University Professors, is a non-stock association composed of professors and teachers from various higher educational institutions.
The association alleged that the university exhibited a hostile attitude toward its formation and engaged in discriminatory, harassing, and intimidating practices against its members.

Upon filing a response, the University of San Agustin denied the charge of unfair labor practice and disputed the jurisdiction of the Court over both the parties and the subject matter.
The trial was held before a hearing examiner, during which respondent additionally argued that the trial should not have proceeded due to the absence of the mandatory preliminary investigation required by law.
Despite these objections, the trial continued and eventually, the case was submitted to the court, which then issued an order directing the case to the Prosecution Division for the preliminary investigation.

The petitioner contended that the complainants, being college and university professors, were not “industrial” laborers or employees.
It was argued that as an institution not established for profit or gain, but solely for educational and religious purposes, the University of San Agustin does not meet the criteria of an industrial enterprise under the relevant laws.
Consequently, the petitioner asserted that any dispute arising between the university and its teaching staff was not an “industrial dispute” and thus was beyond the jurisdiction of the Court of Industrial Relations.

The issues in the present case were compared to those in Boy Scouts of the Philippines vs. Juliana V. Araos, where the Court held that charitable and non-profit institutions are excluded from the ambit of industrial employment laws.
The reasoning in the Boy Scouts case emphasized that labor protection laws, including those governing unfair labor practices, apply only to industrial employment for profit and gain.

Whether the relationship between the University of San Agustin and its professors qualifies as an employer-employee relationship under labor law.
Whether such a relationship falls within the definition of “industrial employment,” thereby triggering the jurisdiction of the Court of Industrial Relations.

Whether the provisions of Republic Act No. 875 on unfair labor practice are applicable to non-profit educational institutions.
If the labor relations in a non-stock, educational institution are governed by the same principles as those in industrial enterprises.

Whether the reasoning in the Boy Scouts of the Philippines case can be analogized to the present controversy.
The impact of prior decisions on determining the scope of labor legislation with respect to institutions organized for educational and religious purposes.