G.R. No. L-29630 - Philippine Commercial and Industrial Bank vs. Philnabank Employees' Association

Petitioners: The University of the Philippines and Concepcion D. Anonas filed a petition for certiorari with a preliminary injunction.
Respondents: The Court of Industrial Relations and associated parties in an action for unfair labor practice.
Underlying Complaint:

The unfair labor practice complaint was filed by an acting prosecutor of the Industrial Court on behalf of the respondent labor union and its complaining members—Fabiana Borines, Epifania Abijay, and Alicia Ebalo.
Allegation: Petitioners, by not “reappointing” the three temporary employees, discriminated against them in retaliation for their demands for better working conditions.

The petitioners denied the charge of unfair labor practice.
They argued that the employment of the complainants, as helpers in the UP Women’s South Dormitory, was temporary in nature.
Termination was justified on the grounds of negligence, insubordination, and disloyalty as determined by an investigating committee.

Before the merits were heard, petitioners filed a motion to dismiss on the ground of lack of jurisdiction.
The argument asserted that the University of the Philippines is an agency of the State performing governmental functions, is a non-profit organization, and thus not subject to the provisions of Republic Act No. 875 (which governs labor disputes and unfair labor practices).
The Industrial Court denied the motion to dismiss.

After entering appearance as counsel for the petitioners, the Solicitor General filed a motion for reconsideration of the court’s order denying the motion to dismiss.
The Industrial Court, however, resolved to deny this motion as it was filed beyond the 5-day reglementary period.
Subsequent reconsideration of that resolution was also denied, prompting the petition for certiorari before the Supreme Court.

The University of the Philippines was established “to provide advanced instruction in literature, philosophy, the sciences, and arts, and to give professional and technical training” (Act 1870, sec. 2).
As a government-maintained institution of higher education, it is not organized for profit and does not distribute dividends.

The Court referred to the decision in Boy Scouts of the Philippines vs. Araos (102 Phil. 1080), which held that labor legislation, from Commonwealth Act No. 103 to subsequent labor laws, was intended to apply only to industrial employment for profit-making organizations.
The principle was reiterated in University of Santo Tomas vs. Villanueva and other related cases, confirming that non-profit educational and governmental institutions are outside the ambit of such labor laws.

Whether the Industrial Court has jurisdiction to entertain and decide a complaint for unfair labor practice filed against the University of the Philippines and Concepcion D. Anonas, given the nature of their functions and organizational status.

Whether the complaint sufficiently states a valid cause of action, particularly when the complainants were temporary employees whose appointments naturally terminated.
Whether the alleged non-reappointment constituted an unfair labor practice or was a justified termination based on factors such as negligence, insubordination, and disloyalty.