Case Digest (G.R. No. L-12222)
Facts:
University of San Agustin v. Court of Industrial Relations, G.R. No. L-12222. May 28, 1958, Supreme Court En Banc, Bautista Angelo, J., writing for the Court.The petition arises from an unfair labor practice complaint filed by the Philippine Association of College and University Professors against the University of San Agustin before the Court of Industrial Relations (CIR). The University is a religious, non‑stock corporation organized for religious and educational purposes and not for profit; the Association is a non‑stock organization of college and university professors. The Association alleged that the University adopted a hostile attitude toward its formation and discriminated, harassed and intimidated its members.
In its answer the University denied the unfair labor practice charge and challenged the CIR's jurisdiction over both the parties and the subject matter on three grounds: that college and university professors are not "industrial" employees; that the Association is not a labor organization within the meaning of the statutes creating the CIR; and that the University, as a non‑profit educational institution, is not an "industrial" enterprise subject to CIR jurisdiction (citing, inter alia, U.S.T. Hospital Employees Association v. Sto. Tomas University Hospital, 95 Phil. 40, and San Beda College v. Court of Industrial Relations and National Labor Union, 97 Phil. 787).
A hearing examiner proceeded with trial without prejudice to the jurisdictional questions; during the proceedings the University additionally urged that the CIR could not proceed without a prior preliminary investigation required by law. The trial nevertheless continued and the case was submitted for decision. On January 2, 1957 Judge Jose S. Bautista of the CIR issued an order holding that, although a preliminary investigation was required, the CIR nevertheless had jurisdiction and directed the case to be endorsed to the Prosecution Division for that investigation. The CIR en banc affirmed that order (Judge Lanting took no part; Judge Martinez concurred in the result).
The University then filed the present petition for review in the Supreme Court challenging the CIR's order and resolution. The appeal presented the substantive question whether the CIR has jurisdiction to entertain unfair labor practice complaints against a non‑stock, non‑profit educational institution and its teaching staff,...(Pro-only)
Issues:
- Does the Court of Industrial Relations have jurisdiction to entertain an unfair labor practice complaint against a non‑stock, non‑profit educational institution and its professors?
- Do the provisions on unfair labor practice (Republic Act No. 875) apply to the employment relation between a non‑profit educational instituti...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)